What The OIG Wants Medicare to do to Find Fraud Among EHR Users

Health Systems Management Network, Inc. has been advising clients for 30 years through every iteration of coding and clinical documentation requirements including our most recent one (see our article on clinical documentation) advising our clients that “Cut and Paste” documentation is not only a compliance problem today but also for the transition from ICD-9 to ICD-10.  In the new scenario the vast differences in clinical documentation requirements are cavernous.

HSMN has been providing clients with prospective views of their current inpatient and outpatient clinical documentation and coding.  What HSMN has found is that some of its clients are in danger of noncompliance.  The OIG recently recommended that private companies that process or investigate Medicare claims on behalf of the government begin examining audit logs of EHR systems in order to better detect fraud.  Even more disturbing is that what some of the clinical practices have found among some of its clients will mean substantial loss of income and delays in their cash flow.

HSMN has implemented a program of review that determines current vulnerability and provides a management plan to fix the problems on an ongoing basis.  It begins with our review of the Audit log in the EHR and a prospective review before billing for current active cases in all of the settings in the hospital and ambulatory care.  The review also compares current documentation practices with the requirements of ICD-10 transition.

HSMN clients have found this an effective way to let the medical staff understand where the gaps are in Clinical Documentation for both the hospital and the professional fee sides of the reimbursement equation.

HSMN addresses how “the cut and paste” issues in the EHR must be handled.  HSMN reminds all of the players, especially medical staff members that no two patients are identical and all patients must be differentiated in documentation.  Also with respect to the E &M requirements HSMN works closely with the medical staff on these issues.

HSMN clients have often asked us to work through their compliance departments and or counsel to assure that all is done properly in these reviews.

To contact HSMN regarding the EHR OIG audits and the transition to ICD 10 you may reach us by phone 866-908-4226 or fill out our contact form contact us.