by AJ Riviezzo
There has been a good bit of debate on the AVLS Member’s Community board regarding when conservative therapy begins. Here is my ‘take’ based on what I have seen transpire during RAC audits.
Many practices believe if you document the patient’s word regarding use of stockings that this will suffice. It will not for several reasons –
a. You cannot typically document if these were 20/30 compression stockings or just something purchased at a large box store.
b. We have appealed claims based on this issue that were denied by the Administrative Law Judge who told us the patient’s self-report was insufficient.
c. Conservative therapy has other elements. Novitas’ policy states a three-month trial of conservative therapy to include not only compressive therapy, but also exercise, periodic leg elevation, weight loss and avoidance of prolonged immobility – which has failed. If these elements are not being supervised by a physician it cannot be documented if the measures were successful or if they failed. There is more to conservative therapy than just stockings.
The RAC auditors are not well-versed in the treatment of varicose veins. They have a check list derived from the different Local Coverage Determinations (LCD’s) or policies by the different Medicare Administrators (MAC’s). If your documentation does not match the expectations outlined on the checklist, they are happy to fail you on the audit as it has been noted to me that these companies are paid by Medicare based on their negative findings.
Using Noridian’s LCD, it states that conservative therapy has to have failed. This implies that a note from an office visit must be in the chart stating said failure. We have seen some audits fail due to the lack of this type of post conservative therapy documentation. Unlike some other LCD’s, Noridian does not have a variance or waiver of conservative therapy for high CEAP scores. It is important to very carefully read and understand the LCD for your area.
In short, to ensure you pass a RAC audit we strongly recommend knowing your MAC’s expectations, documenting to that standard, and performing the conservative therapy yourself.
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