Medicare Blog

what causes a medicare audit

by Buford Carter Published 2 years ago Updated 1 year ago
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The fact is that there is some item you have claimed as a Medicare provider or the amount of claims Medicare has paid in a certain category that has caused you or your practice to be audited. Having too many claims for level five CPT codes might, for example, cause you to be audited. Having multiple claims submitted for the same date of service, may cause you to be audited.

What Triggers a Medicare Audit? A key factor that often triggers an audit is claiming reimbursement for a higher than usual frequency of services over a period of time compared to other health professionals who provide similar services.

Full Answer

Can I avoid a Medicare audit?

Jul 16, 2014 · As you know, Medicare policy is a web of super-confusing rules and regulations. But for PTs, the majority of audits result from one of the following triggers: Excessive (i.e., above the norm) use of the KX modifier, which signals an automatic exception to the therapy cap on the basis of medical necessity

What triggers Medicare to audit Pts?

The fact is that there is some item you have claimed as a Medicare provider or the amount of claims Medicare has paid in a certain category that has caused you or your practice to be audited. Having too many claims for level five CPT codes might, for example, cause you to be audited. Having multiple claims submitted for the same date of service, may cause you to be audited.

What happens if I don’t comply with an audit?

Jan 06, 2015 · There are mainly three types of audits — Recovery Audit Contractor (RAC) audits, Certified Error Rate Testing (CERT) audits and Probe audits. Mistakes in medical documentation, coding and billing can rouse Medicare’s suspicion during audits, which can lead to claim denials. Let’s take a detailed look into audit types and the practices that trigger suspicions.

What is a CERT audit and how does it work?

Jun 15, 2021 · CMS may conduct audits of providers based on billing irregularities, issues related to record-keeping, or other concerns about potential noncompliance. During these types of audits, providers will want to understand the process that will be followed and the requirements they must meet.

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What happens when you get audited by Medicare?

Medicare audits are one of several things that can trigger a larger civil or criminal investigation by federal law enforcement. Usually, auditors con- clude that Medicare has made significant “over- payments”and demand that the audited physician return the money.

What do Medicare auditors look for?

According to the CMS website, CERT audits are conducted annually using “a statistically valid random sample of claims.” Auditors review the selected claims to determine whether they “were paid properly under Medicare coverage, coding, and billing rules.”Jul 16, 2014

What will a Medicare auditor check during the audit?

In addition to medical records, auditors often ask for invoices and purchase orders for the drugs and medical supplies dispensed to patients for which Medicare reimbursed you. Include a copy of the complete record and not just those from the dates of service requested in the audit letter.

What is Medicare audit?

The Medicare Fee for Service (FFS) Recovery Audit Program's mission is to identify and correct Medicare improper payments through the efficient detection and collection of overpayments made on claims of health care services provided to Medicare beneficiaries, and the identification of underpayments to providers so that ...Dec 1, 2021

What triggers a Medicaid audit?

Medicaid is federally prohibited from paying providers who are not correctly enrolled with them. Repeated claim submissions that include the use of non-enrolled providers will most certainly raise the Medicaid audit red flag. There can be many reasons that a provider might not be enrolled with Medicaid.Sep 1, 2021

What happens if you fail a Medicare audit?

If you fail to comply with the request, you will not receive reimbursement for the submitted claims. Even if you comply but the documentation doesn't support what you billed for, you won't get reimbursement.Jan 6, 2015

How many years back can Medicare audit?

three yearsMedicare RACs perform audit and recovery activities on a postpayment basis, and claims are reviewable up to three years from the date the claim was filed.Nov 1, 2015

Are Medicare audits random?

For example, the Medicare program is required to make random audits of 10% of all Medicare providers on an ongoing basis. An audit or investigation can result from complaints by patients about the quality or appropriateness of the care they received, or how they were billed for their care.May 18, 2021

Who audits the coding of Medicare patient records?

The Centers for Medicare and Medicaid's audit program is administered by a recovery audit contractor in each of four regions of the United States. Cardiovascular procedures made up the lion's share of miscoding everywhere but the western region, as of 2013.

What are the 3 types of audits?

There are three main types of audits: external audits, internal audits, and Internal Revenue Service (IRS) audits. External audits are commonly performed by Certified Public Accounting (CPA) firms and result in an auditor's opinion which is included in the audit report.

Who audits Medicare claims?

One of the primary tasks of the SMRCs is to conduct nationwide medical review as directed by CMS. SMRCs will evaluate medical records and related documents to determine whether Medicare claims were billed in compliance with coverage, coding, payment and billing guidelines.

What triggers RAC audit?

RAC audits are not one-time or intermittent reviews and can be triggered by anything from an innocent documentation error to outright fraud. They are part of a systematic and concurrent operating process that ensures compliance with Medicare's clinical payment criteria, documentation and billing requirements.

What forms should be included in a nursing home discharge?

Consent forms, medical history questionnaires, histories, physicals, other physicians' orders, all may be a crucial part of the record and should be included. If hospital or nursing home discharge orders or other orders referred the patient to you, obtain these to provide to the auditors.

Do auditors ask for medical records?

In addition to medical records, auditors often ask for invoices and purchase orders for the drugs and medical supplies dispensed to patients for which Medicare reimbursed you. Include a copy of the complete record and not just those from the dates of service requested in the audit letter.

Should Medicare contractor be taken seriously?

All correspondence from Medicare, or the Medicare contractor, should be taken seriously. Avoid the temptation to consider the request from Medicare, or the Medicare contractor, just another medical records request. Avoid the temptation to delegate this as a routine matter to an administrative employee.

Is Medicare a routine audit?

Although you may speak of a "routine" Medicare audit, there is really no such creature. This is like saying you have a "routine IRS audit." The fact is that there is some item you have claimed as a Medicare provider or the amount of claims Medicare has paid in a certain category that has caused you or your practice to be audited.

Is a summary a substitute for medical records?

The summary is not a substitute for the medical records, but will assist an auditor that may not be experienced in a particular specialty or practice area. Make sure that any such summaries are clearly marked as summaries with the current date they are actually prepared. Label it accurately.

Can you alter a medical record after an audit?

Never alter the medical records after a notice of an audit. However, if there are consults, orders, test reports, prescriptions, etc., that have not been filed into the chart, yet, have these filed into it, as you normally would, so that the record is complete.

What is a ZPIC audit?

ZPICs have oversight of Medicare A and part B, hospice care, home health and durable medical equipment (DME). A ZPIC audit is different than a RAC or MAC audit. The primary purpose of a ZPIC audit is to identify fraud, and while this makes ZPIC audits more serious than most, bear in mind that these audit targets are selected based on sample data analysis.

What is CERT program?

CMS developed the CERT Program to produce a national Medicare FFS improper payment rate. After the claims process, CERT randomly selects a statistically – valid sample of Medicare FFS claims and requests documentation from the provider/supplier that submitted the sample of Medicare FFS claims.

What is the purpose of a recovery audit?

The purpose of the Recovery Audit Program is to detect and correct past improper payments (over/under payments) so that MACs can recover overpayments and implement actions that will prevent future improper payments. A Recovery Audit is done on a post payment basis, however the Recovery Auditor will not review previously reviewed claims that were done by another entity.

What is CMS's program integrity strategy?

CMS is developing a “unified program integrity strategy” that merges some Medicare and Medicaid audits and investigations, exploits data mining and aligns the work of regional contractors with CMS’s vision.

What is a probe in DME?

DME MACs conduct PROBE (pre-payment reviews) for certain types of claims that have a history of high rates of improper payments. A “development” letter will be sent to the provider/supplier requesting additional documentation before paying claims.

What does a Recovery Audit Contractor (RAC) do?

RAC's review claims on a post-payment basis. The RAC's detect and correct past improper payments so that CMS and Carriers, FIs, and MACs can implement actions that will prevent future improper payments.

What Topics do RAC's Review?

Stay in the know on proposed and approved topics that RAC's are able to review. These topics will be updated monthly on the RAC reviews topic page and include:

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