I would like to make things right the first time so often, that they have errors and I need to make corrections -and the same is true for providers.
In this post, I would like to approach the topic of addendums. The thing about addendums is… there are no clear-cut rules – except how to create them. What isn’t clear is what services can we create addendums for and what are the guidelines on how far back addendums can be made? Those are the gray areas that circle addendums for which we need to have policies within our organizations, and those policies need to be adhered to, not only by the providers when they create the addendums, but also by us as auditors as we audit the records and review those addendums.
We know the basic rules about addendums when they’re created; they must be separate from the original note, it has to be initialed and signed by the creator of the addendum, and they must be dated with the date that the addendum was created. Now, let’s talk about those gray areas. How far back can a provider go and create an addendum? So, the “grayness” that’s there is Medicare as our “gold standard”. Does it really have a rule on how far back we can go? We kind of have always said that if the provider can remember that, for example, she had on an orange shirt with a white sweater with a beautiful NAMAS logo, then, of course, the provider could make an addendum. It would be best to have some type of a policy within your organization. We’ve tended to err on the side of if the claims already posted and already dropped, then it could have the smell of fraud if the provider is then posting an addendum. Let’s assess this a little bit; If it’s a flagrant error, it still needs to be corrected. If the note says it was the right arm and it was obviously the left, those errors need to be corrected, but if the provider maybe forgot to document work that was performed, and we’re querying the provider to find out if there was work that was performed or if they failed to document consent on a telehealth visit or time on something, then those types of errors of omission…maybe those should be in your policy to not be queried of the provider after the claim has dropped. Now, that goes into our second question: what queries of addendums should be allowed, what shouldn’t, and what services should we allow addendums for and not? There’s no rule by CMS or OIG or anyone else on what addendums are allowed or not allowed for. So again, you could addend critical care service even though that is one of the most high-ranking services that are performed, especially in the E&M world, or even a level 5, or as I mentioned, a telehealth service. So, wherever the provider documented the telehealth service, it was documented that the video was used, it was documented to everything that I needed except the provider failed to document that consent was obtained, and the provider said, “I clearly remember I consented this patient, I just failed to document that I consented the patient”. Can we allow that provider to addend the note? Remember, we did the session not too long ago about the intent versus the mechanics of the code (watch the video here and read the blog post here). What is the intent of the addendum? A provider is just like us. Human error happens and that is why an addendum is allowed — to correct human error and to allow the physician to add additional information. So, should we penalize the provider and not allow the provider to addend a record simply because it’s a consent? So, my frank and earnest answer is no, we shouldn’t penalize the physician. If our provider is willing to say “I remember that patient, she had an orange shirt, white sweater with a beautiful NAMAS logo. I remember that crazy girl”, then we should allow the provider to document that addendum. What is the intent of the addendum? Why are we creating an addendum? If the intent of the addendum is to increase the level of service or increase the billable only, that’s inappropriate. However, if it’s a one-off, if we don’t have a trend, if we don’t have a pattern, that’s what we look for. As auditors, our job supersedes the “one-off”. That’s not what we’re looking for. That’s a rarity. We’re looking for trends and patterns. You’ll notice that a lot of our cohorts are turning into “analysts”, or their jobs are called “analyst” now. That’s because trends and patterns and math are becoming part of our jobs. What’s the trend and pattern with your physician addendums? Are there more addendums than not, or is it a “one-off”? So, the next time you see an addendum, ask yourself about that provider. Why was the addendum created? How long after the date of service was the addendum created, and is this a “one-off”? I think then you would then have a better opinion of why the addendum should or should not be counted (and make sure you have a good policy). Vet that policy and have compliance weigh-in to make sure that it’s a good all-around policy, not just for the auditing team or the compliance team, but also to work well for your physician and provider team as well.
