RE I MB U R SE ME NT & C LINICA L ISSUES
AUDITS ONLY AFFECT THE SUPPLIER : A MYTH Written by: CLAUDIA AMORTEGUI
“We were paid” - “We have a prior authorization” - “We have documentation” - “My patient is happy” – these are all comments I hear people say rather confidently when I start talking about audits. For those of you who know me, you will likely recall my response – “just because you were paid does not mean it’s right.” Let’s start with the basics. All funding sources clearly state an approved prior authorization is not a guarantee of payment. That includes the initial payment or even if they choose to recoup a payment due to an audit. An approved prior authorization does give a supplier a leg to stand on, but it will depend on the problem the insurer claims to have found. When it comes to Medicare, there are two types of “Prior Authorization” in the world of Complex Rehab Technology (CRT). For the CRT manual wheelchairs, there is a process called Advance Determination of Medicare Coverage or ADMC. In my opinion, this is the best one because the supplier will receive an approval or denial for each line item that will be billed on that order. For power wheelchairs, there is the Prior Authorization Program. This program was a big win for CRT, but one key issue is they currently do not provide a line-by-line decision. Technically, the approval/denial is for the power wheelchair base only. A while back Medicare did announce if an approval was provided, it could be assumed the approval would also relate to powered seating if the base code submitted included powered seating. For example, if a K0861, Group 3 multiple power option power wheelchair base is approved, a supplier could assume the approval is for both the base and the power tilt and recline (if they are on the order). However, there is no guarantee for anything, let alone all the other billable options. This part should concern suppliers. In my opinion, people are getting very comfortable with the payments when there are many orders that would or should fail an audit.
DON’T EVER THINK THAT GETTING PAID IS THE MOST IMPORTANT PART OF THE PROCESS.
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DIRECTIONS 2021.6
What does this mean for the clinicians or even the funding sources? First, for clinicians, although a recoupment of a payment is not money out of their pocket, it can certainly affect their patients. The coverage and payment of future repairs would be an issue. As for the funding sources, their audits can come back and affect more than just the one supplier. If they find an opening and see consistency in claim errors, it can slow down future claims for the same item for all suppliers. To take this a step further, if suppliers do not appeal the denials appropriately, certain insurers can start “interpreting” their own policy incorrectly. Their thought is if suppliers are not arguing incorrect denials or recoupments, then it must be OK. In these cases, suppliers, clinicians and even end users need to speak up. Sometimes it is just simple education of what a product is or even what the documentation means. CRT is just that, complex; we need to be sure everyone understands not only the products but the reason a specific person would medically need an item. When it comes to Medicaid and other insurers, they typically provide approvals for more than just the base. Some will provide a line-by-line approval or denial, and others may have a code list or dollar threshold for the items not requiring prior authorization. In either case, they clearly state on every authorization that suppliers can still receive a denial – which also means,a recoupment in an audit. No matter the insurer, audits are happening. They are reviewing many parts of the healthcare industry including equipment orders and telehealth visits. This includes the documentation for both. Suppliers need to be sure they are thoroughly reading all the documentation. By doing this, it not only helps in avoiding possible denials, but it also gets you prepared for an audit. Keep in mind seating evaluations should not contain information that contradicts what is in the ordering practitioners (MD, DO, NP, PA) chart notes.
