Coding Inaccuracies That May Put Orthopedic, Spine and Pain Management-Driven ASCs at Risk With the OIG and RACs

Cristina Bentin, CCS-P CPC-H CMA, president of Coding Compliance Management, gave a presentation titled "Coding Inaccuracies That May Put an ASC or Practice at Risk With the OIG and RACs-Pain Management medical Necessity/Over-Reporting, Orthopedic Incorrect Reporting on Knees and Shoulders, Spine Overstating Work/Unbundling" at the 9th Annual Orthopedic, Spine and Pain Management-Driven ASC Conference in Chicago on June 11, 2011. Over the past few weeks, Ms. Bentin has heard from an increasing number of ASCs who received letters of demand from RAC auditors about inaccurately billed claims. While some of the letters could be rightfully contested, others rightfully found intentional or unintentional upcoding, which is a costly mistake for the ASC.

When an ASC receives a letter of demand, you have the opportunity to converse with the auditors and contest the fee. Coders must be able to defend their work by pointing to the operative documentation and coding guidelines. Right now, RACs seem to be identifying claims with the same CPT coded twice as mistakes. There are some occasions where capturing the same code twice is appropriate, and identifying those instances will become increasingly important in the future.

To avoid coding mistakes, Ms. Bentin recommends:
•    Conducting internal audits
•    Giving staff members appropriate time to analyze claims before they are sent out
•    Continuing education courses for coders

It's imperative that coders aren't rushed to finish a quota of claims because they need to have time to make sure claims are accurate. Coders must be able to decipher Medicare from commercial payor claims and understand the utilization of Medicare edits. Surgeons also need to write clear operative notes and be ready for a conversation with coders about the specificities of unusual or complex cases.

Related Articles on Orthopedic and Spine Coding:
Surgery Center Coding Guidance: Ankle Lateral Ligament Repair
Surgery Center Coding Guidance: X-Stop Procedure
3 Points on Bundling Fluoroscopy Into Pain Procedures

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