March 2010
Practical Documentation: Doing the right thing the wrong way can cost you
Examples of doing the right thing the wrong way happen every day in chiropractic clinics across the nation.
It happens when you attempt to do the right thing for patients with no insurance or limited benefits by “tweaking” your documentation and coding to result in an overall lesser charge for the patient.
For example: A patient comes to see you and requires more than a routine workup. Since this patient has no insurance coverage, you decide to use a lower level exam code, perhaps a 99201 for the initial examination instead of a 99202 or higher.
How about a patient you treated in four spinal regions, but only documented one or two levels and charged for a 98940? What about a Medicare patient that required a detailed workup including x-rays and you charged a lower level exam code and a two-view x-ray series when you actually performed four, all because Medicare doesn’t cover exams or x-rays? No big deal, right? Wrong!
Documentation faux pas
Down coding your services in an attempt to strike a balance between what insurance coverage may allow and what you feel your cash or underinsured patients can afford are actually documentation faux pas.
If you don’t report what you did and don’t charge for services you would normally bill to insurance because you are seeing a cash or underinsured patient, that creates the potential for fraud because of a dual standard of care and a potential dual fee schedule.
Even worse, the Office of Inspector General (OIG) and United States Department of Health and Human Services (HHS) considers down coding or failure to bill a Medicare patient’s accurate services an inducement and is subject to serious fines and penalties.
Because you must document what is done and bill for all the services provided in order to stay profitable and in practice, you’re often out of compliance when trying simply to do the right thing. Be sure to document what you do, everything you do, and then code and bill it properly.
Ultimately, down coding and under-documenting is perceived as illegal and inappropriate, just as up coding is when it is used to allow you to bill differently based on whether it is an insured or cash patient.
Documentation of necessity means just that. Don’t let your perceived need to maximize reimbursements by billing your UCR fees or contract rates to insurance companies, but not to cash or underinsured patients. Don’t presume the correct way to make this right is to downplay your service by
What you can do
So how can you document, bill, and code properly for maximum reimbursement when there is insurance available and still be able to help cash patients? Join a cash discount program and encourage your patients to do the same.
It is one of the most logical, legal, and ethical ways to allow you to accept a lower fee than your normal clinic fees. It allows you to have a contracted fee schedule for your cash and underinsured patients, just like your other managed care networks.
The contract model is not new and is what allows you to contract with multiple insurance companies for different rates for the same codes without it being a “dual fee schedule.” Cash discount plans simply provide the protection of a contract and allow you to document, code, and bill properly, and still pass on some savings to your cash and underinsured patients.
If you are already documenting, coding, and billing properly, great! Just make sure you don’t do the right thing the wrong way by trying to use a bookkeeping reduction or time of service discount that may be out of the range considered reasonable by your state. Too many clinics use these tactics or strategies improperly in trying to help cash and underinsured patients.
Doing nothing is not an option. Don’t run the risk of unwittingly committing fraud by having a dual fee schedule or shaving your documentation to help your cash or underinsured patients. It’s not hard to do the right thing the right way.
Kathy Mills Chang is the founder of her own consulting firm, assisting doctors with finding financial and reimbursement ease in practice and helping them to make and keep more money. She also serves as Foot Levelers’ insurance advisor. She can be reached at kathy@kathymillschang.com or through www.kathymillschang.com.
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Documentation checklist
Run through this checklist as you take a look at your current billing and documentation habits.
1. Do you tend to under-document for your cash patients?
2. Do you think that if your documentation doesn’t have to be sent anywhere you can get by with limited notes?
3. Do you have dual fee schedules by having one set of fees for personal injury, out-of-network insurance, and others, and another for cash patients?
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