Recently I received an email from an auditing group to which I belong that offered some nasty little tips that auditors can use to easily recoup money from physicians, including chiropractors.
First, let me pause and clarify one point. Although I do have a certification as a professional medical auditor (and as of this writing am the first and only chiropractor to do so), I do not use this to audit chiropractors. In fact, I received this training so that I can more fully understand what auditors are looking for and to protect YOU. Today’s blog post is a perfect opportunity to use this.
Back to the email…
This email particularly struck me because the auditing tips contained within it were so basic, simple yet powerful tools that auditors could use against us as providers. And here it is:
The email reminded auditors to be vigilant about checking documentation dates.
3 Documentation Date Errors to Avoid
Specifically, the reminder included three potential ways to deny services or recoup payments for documentation date errors or “failures.” Turning this around for your defense, here are three ways to AVOID post-payment demands or getting your services denied for documentation date problems:
1. Be sure that the date of documentation matches the billed date of service
2. Be sure that dictation or transcription dates meet timely filing requirements
3. Be sure that publication or “time-stamp” dates (if you are using EMR) meet timely filing requirements
That’s it! Simple, perhaps even obvious, but deadly if a mistake in these areas are made. And since auditing is a volume-based business where the more claims an auditor can review and deny, the better they are paid, you can bet that an auditor can use these items against you in 2 seconds flat!
Check Your Chiropractic Documentation — Before Problems Occur!
Here are the specifics:
1. Date of Documentation Matching Billed Date of Service. This should be a basic item checked before all claims are sent out. If your documentation states that you saw the patient on 3/2 and your HCFA goes out billing for a 3/1 date of service, your claim can be denied or demands made by the payer for their money back. Since the majority of the time this occurs, it’s due to a simple error, the remedy is to simply check claims before the go out the door. If you think this slows down the process, it does. But the increased time and expense for making sure it goes out correctly is less than the time and expense when it is denied. Now you are dealing with lost income, time to research why the denial was made, submission of a corrected claim (assuming it was a simple clerical error), delay in waiting for payment and re-processing, coordination of benefits by the insurance company and then processing the payment, balancing and updating the patient’s account. In other words, one extra step on the front end compared to at least 7 extra steps when re-processing is required.
2. Dictation/Transcription Date Meets Timely Filing Requirements. Most payers have time requirements for how long after the date of service your documentation can be completed and still be considered “on time.” This is an often neglected area in your insurance contracts and, admittedly, was one that was probably never enforced in “the old days.” Times have changed. Auditors are now trained to look closely at the date of service and see whether the transcription/dictation dates were submitted in a timely manner. In other words, how long did it take you to dictate the note.
3. EMR Publication/Time Stamp Date. Similar to item #2, auditors are now being trained to look at when your note was completed via your EMR system. Many EMR programs come with automatic “time and date stamping” to prevent unauthorized or fraudulent alteration of records and a verification of the authenticity of the visit. However, this feature can be used against you if you do note complete your notes in a timely fashion.
What is Timely Documentation?
Since both Item #2 and #3 hinge on completing documentation on time, the natural question becomes: “What exactly is timely documentation?”
The precise answer is: “It depends.” A more helpful answer is that most payers have documentation requirements that range from 24-72 hours after the service has been rendered. The specific requirements for timely documentation can vary from payer to payer and are typically tucked away amidst a bunch of other legalese somewhere deep within the bowels of your provider contract and/or the payers’s medical reimbursement policies.
In this respect, one payer can require a 24 hour time period for timely documentation, while another may be more “generous” and permit 48 or even 72 hours. (A 24 hour timely completion requirement would mean that if you saw the patient at 3pm Monday, your documentation would need to be complete by 3pm Tuesday.)
For those of you who are in the bad habit of leaving piles of documentation unfinished until requested by a payer, this is very disturbing news I am sure. Essentially what this may also mean is that much of your documentation fails to meet the basic requirements for reimbursement (no matter how good it may be) due to the fact that it was not completed on time.
Auditors are well aware of this fact since chiropractors are not the only physicians with the bad habit of completing notes only when necessary. As a result, they are being encouraged to check your documentation to see if it meets time requirements. If not, no further examination of your notes is required. Your claim will be denied. If you were already paid and the auditor is performing a post-payment review, they will demand that you return the reimbursement for that visit.
Steps to Protect Yourself
1. Check claims for simple “failure” errors. Sending a claim out with documentation and billed service dates that don’t match is easy to prevent and fairly inexcusable. Check and see that your efforts and money are not wasted.
2. Complete documentation on time. Easier said than done, I know. However, take into consideration that even poorly done notes that are on time, may be better than stellar notes that could be denied due to failure to meet time requirements.
3. Develop efficient documentation systems. Do not translate this to mean: get EMR. Some doctors actually take longer to complete their notes with EMR, mainly because they have chosen a system that does not fit their learning or treatment style. In other scenarios, an EMR may help speed things up tremendously. The common factor, however, that I see behind good documentation is independent of whether or not the doctor uses EMR. The best notes that I review (and I see notes from a wider variety of chiropractors in one week than most of you will see in your career) are from doctors who have developed an efficient, consistent SYSTEM of documentation. They have good habits that serve them well and they have repeatable systems in place that they use consistently to product good notes. ( All this sounds like good material for a future post on Efficient Documentation: Do’s and Don’ts!)
Until next time!