by AJ Riviezzo


We perform quite a number of chart audits for phlebology practices throughout the country. We are also asked to assist practices when they are targeted with an audit by Medicare, Blues or one of the commercial plans. As such, we are very aware of what is happening in regards to audits and how practices are failing these audits.


While there are some rather picayune reasons someone may fail an audit, by far the single most common denominator is conservative therapy. In order to ‘get around’ the conservative therapy guidelines many practices note that the patient states they have ‘worn stockings for at least three months’. This somehow negates the need for conservative therapy.


Conservative therapy must be ordered by a physician. The therapy is also not limited to just use of compression stockings, but typically includes use of NSAIDs, leg elevation, exercise and/or weight loss. Palmetto even requires the patient to take venoactive supplements. Even if the patient’s PCP did order the use of compression stockings it is highly unlikely they ordered the other elements.


If an auditor rejects your conservative therapy measures as inadequate or unperformed, ALL of your subsequent procedures may be rejected. Further, if they find a few charts like this, they are likely to expand the audit. If a good percentage of your expanded audit is found wanting, we have even seen a payer apply that percentage to all claims performed by that practice for the past three or more years which is a very substantial recoupment in most cases.


We most strongly recommend that the rendering physician orders the conservative therapy in the History and Physical as one of your Plan orders to include the necessary elements of the conservative therapy requirements for that payer (duration, stockings, NSAIDs, leg elevation, etc.). We also recommend bringing the patient back or calling and documenting the call mid-way through the conservative therapy window. This helps in two ways. First, the therapy is being monitored by the physician and is documented by someone on their team. Second, the patient is reassured and reminded about their upcoming appointment. Finally, you should bring the patient back for at least an office visit to review how well conservative therapy corrected or failed to correct the patient’s condition. If it failed, then the physician should outline their course of treatment.


Should your practice be one that has not been rigorously ordering conservative therapy, it can be very financially difficult to suddenly shift to this process. At a minimum, begin moving a third of your Medicare and Blues patients into this format each month for three months. You should have sufficient patient volume to move forward appropriately from then on.

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