How many charts have you guys already audited in 2023? That’s a really big question. I hope you’re already starting to discuss your audit plan for 2023. It’s not too early, and I hope you’ve already started actually auditing charts for 2023.
I recently sent out an audit tip that addressed productivity and quality production standards for auditors and what your expectations could be and should be for your team for 2023. (NAMAS Audit and Documentation Tips come out every Friday through email. If you’re not signed up for those, visit our website and get signed up to receive these tips!)
In Today’s Take, I wanted to talk to you about what you should think about for your audit plan for 2023. I recently had an e-mail question from someone potentially changing their audit plan for 2023. The first question was “does our audit plan need to change every year?” That’s a really great question, and in theory, the answer is no. You can repeat the same audit plan year over year. There’s no need to necessarily change your audit plan. There’s no rule that says your audit plan has to change. However, the value in sometimes changing your audit plan is to make sure you’re approaching compliance in different ways, and ensure that things don’t become sedentary in your audit plan and in your compliance plan. If your providers know that you’re getting ready to audit them, and they know you’re going to pull that sample, and they know from what pile of charts you’re going to pull that sample, I bet there’s going to be improvement in the documentation in that segment. You might want to put some variation to your plan. However, your audit plan could be the same. I am going to encourage you to look outside the box and how you could change things up. For example, if you’ve been performing E&M baseline audits, have you considered a risk-based audit? Risk-based is when you’re not doing just a baseline audit, but instead, you’re looking at where your risk is and auditing on risk as opposed to a baseline. This can potentially save you money as you’re really focusing only on where your risk is instead of just auditing, just in theory, just a baseline audit. (For more information, you can visit Frank Cohen. He can tell you some more information about that or contact me, and I can give you some more information on specifics with risk-based auditing.)
The next question asked about physicians only wanting to include E&M service and wondered if this is a wise approach to audits. Well, the problem with only auditing E&M services is that those may not be the only services that you’re submitting claims for, therefore, you do have risk in other areas. I encourage you to make sure that your audit plan encourages all services for which you’re submitting claims. If you submit claims for radiology services, physical therapy services, 25 Modifier…whatever services you submit claims for, you should include those in your sample services. Make sure that you’re encompassing your audit plan and everything that you’re doing, every audit, each year.
The last question in this email explained that their partner providers deferred the audit this year, and only the associates were to be included in the audit. The email went on to ask if this is allowed. Remember that all providers should be included in the audit annually as part of an active ongoing compliance plan. That would include our partner providers as well as associate providers within those smaller physician practices. Regardless of the size of a health system, a small practice, a large practice, whatever the size, all providers should technically be audited annually in order to meet the definition of an ongoing compliance plan.
If you have questions about your ongoing audit plan, feel free to send those to me or to any member of our team here at NAMAS. We’re more than happy to help you and see if we can help in making sure that your audit plan is going to “cut the muster” for 2023!
Visit the NAMAS YouTube channel to view the video of Shannon DeConda discussing this topic.
Your next steps:
- Schedule a consultation for 2023 audit planning and a provider documentation review.
- Read more blog posts to stay updated on the 2023 Revisions to the 2021 E&M Guidelines.
- Subscribe to the NAMAS YouTube channel for more auditing and compliance tips!
NAMAS is a division of DoctorsManagement, LLC, a premier full-service medical consulting firm since 1956. With a team of experienced auditors and educators boasting a minimum of a CPC and CPMA certification and 10+ years of auditing-specific experience, NAMAS offers a vast range of auditing education, resources, training, and services. As the original creator of the now AAPC-affiliated CPMA credential, NAMAS instructors continue to be the go-to authorities in auditing. From DOJ and RAC auditors to CMS and Medicare Advantage Auditors to physician and hospital-based auditing professionals, our team has educated them all. We are proud to have helped so many grow and excel in the auditing and compliance field.
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