Audit Tips for the Ophthalmic Professional

In December, Ophthalmic Professional’s sister publication Ophthalmology Management asked expert Medicare consultant Riva Lee Asbell and health-care lawyer David Laigaie to compose a guide for doctors embroiled in an audit. We went back and asked them what allied health professionals need to be mindful of in the event this stressful situation knocks on your practice’s door:

Riva Lee Asbell, Fort Lauderdale, FL

1 Educate Yourself.

Educate yourself on Medicare’s various types of audits so you can recognize the request for records that may have more serious implications for your practice. Consider these resources:

■ Webinars given by Medicare Administrative Contractors (MACs)

■ Various publications on Medicare Learning Network

■ MACs e-mail notifications

2 Assist in Physician Education.

Educate physician(s) on the importance of their role in audit response. Note the following details in particular:

■ It is important for the physician to review the request.

■ Physician(s) should ascertain that the records are complete and include copies of pertinent diagnostic tests with a properly executed Interpretation and Report.

■ Physician(s) should make sure the rationale for Medical Necessity is present in the chart documentation–if not, add supplementary material.

3 The Devil is in the Details.

■ Make sure all orders for diagnostic tests are in place.

■ Make sure all scribing rules are followed.

■ Make sure all signatures are in place, if not do not add to the document –be sure to use an attestation statement.

— Riva Lee Asbell is a nationally recognized consultant on coding and compliance issues. She can be reached at rivalee@aol.com or through her Web site: www.rivaleeasbell.com

David Laigaie, Philadelphia, PA

1 Assign an audit liaison.

Assign one person for all audits. Make sure all audits are immediately forwarded to that person. This person should not be a physician.

2 Locate all files.

Search diligently for all responsive documents. Sometimes they’re out of place or not kept with the patient files. All responsive documents must be located and produced.

3 Review.

Look at the documents. Identify any problems. Get counsel or the compliance consultant involved if there are serious deficiencies.

4 Do not, do not, do not!

■ Do not alter the documents or create new, supplemental documents.

■ Do not sign documents that previously had not been signed (unless the signature is conspicuously and accurately dated).

■ Do not supplement the information in the chart, e.g., add “missing” dates of service, add a diagnosis, include additional information to support medical necessity, or “write in” a missing test or service.

■ Do not include forms, authorizations, consents, transfers of care, etc. that were not obtained when the service was provided.

5 Backup

Keep a copy of all audit requests and all audit responses.

— Mr. Laigaie is a partner at Dilworth Paxson LLP, Philadelphia, where he chairs the corporate investigations and white-collar group. He concentrates in complex civil and criminal litigation, including Federal False Claims Act cases. Mr. Laigaie regularly represents medical providers, suppliers and institutions. He can be reached via e-mail at dlaigaie@dilworthlaw.com or by phone at 215-575-7168. OP