by AJ Riviezzo
There has been an upsurge in the number of phlebology practices receiving requests for medical records from Recovery Audit Contractors (RAC). These contractors are empowered by the Medicare Fee for Service Recovery Audit Program. The keys to this are in the very definitions I believe. First, the good folks doing the audit are contractors and, per my understanding, are paid based on dollars they ‘save’ the Medicare System. Second, the entire program is the Recovery Audit Program. It is not to help educate or guide physicians, it is to recover monies. As such, they are very aggressive and very strict in their interpretations of the various Local Coverage Determination (LCD) policies.
Below are some of the chart audit elements we have been told that are a focus.
Conservative Therapy – You cannot take the patient’s word about having done conservative therapy. You must order the conservative therapy, follow the course of the therapy, and then review the effectiveness of the therapy when it is completed. Be very careful with ‘previous treatment’ as an exclusion to ordering conservative therapy. If the treatment is over a year old, you need to repeat conservative therapy.
Activities of Daily Living (ADL) – The various LCD’s have a requirement that the disease must impact the patient’s Activities of Daily Living. The degree and severity of the impact on the ADL’s varies from LCD to LCD. You need very good documentation that is patient specific regarding the disease impact on the patient. Generic or ‘cookie cutter’ language is insufficient. Our recommendation is to have a place where the patient, on intake, can complete a sentence similar to: “My varicose veins prevent me from _______________.”
Tortuosity – A new one is noting that the veins are not too tortuous to treat. This can be in the diagnostic ultrasound or subsequent follow up notes.
Vein Size and Filling Index – Your diagnostic ultrasound should have actual measurements rather than greater than or lesser than ‘measurements’. It should also have the actual venous filing index noted rather than a non-specific ‘greater than .5 seconds’. Be sure you have multiple measurements of the GSV and SSV. When billing a 93970 bilateral diagnostic ultrasound you need to ensure there is information about the femoral vein contained in the interpretive report.
Interpretive Report – Diagnostic Ultrasounds must have a final interpretation. Simply signing the RVT’s worksheet is not an interpretive report.
LCD Specific Elements – Be sure to carefully read the LCD for your area. Some policies require VCSS, one other requires a BMI measurement, and other similar items that need to be documented.
The above is certainly not an all-encompassing list, but it does give you a few items to consider and review against your own charts.
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