In the last couple of years and certainly in the last 6 months we have seen a lot of audit requests. These have ranged from a simple 1 or 2 chart request from Medicare Advantage plans, to CERT (comprehensive error rate testing) requests, to Medicare pre-payment audits of several patients’ charts, and even a site visit by a commercial payer. In each of these instances one of the first questions asked is what should the practice be doing before record submission to ensure that the audit goes well. The answer is: not much.
The only thing a practice can pro-actively do is to ensure all the notes are signed, and that they send a complete packet. Other than that, there is not lot that can be done. The records cannot be altered as they are a legal document and changing them is one of the first and worst offenses constituting fraudulent activity. For better or worse, the records need to be submitted as they are, with no alterations.
Disheartening? Absolutely! Your only protection as a practice is to be sure that your charts are up to snuff before the insurance asks for them. Audits are real, and becoming more frequent, so if you have any concerns that your records are not sufficient in any way, perform a self-audit, or retain an outside auditing agency to assist in correcting any issues before they are officially requested.
Just like editing your own paper, another set of eyes will typically “see” what you don’t, and may have suggestions you had not thought of. A proactive plan of action is truly the only action your practice can take.
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