Medical Billing Normalization Comparisons

Understanding Medical Billing Invoice Variations

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Deviations in medical billing may often be detected through utilization data that the government or private insurance companies produce on all providers that submit a claim for payment of services. Uncle Sam and insurance companies track utilization through a variety of parameters, including CPT codes, ICD-9-CM, or number of referrals; etc.

Benchmark Differences

However, different programs utilize varying benchmarks to trigger a review. For example, a physician who sees patients in the office from 8:00 a.m. until 8:00 p.m., seven days a week and has the highest billing amounts in the region can be subjected to a review. This doctor’s activities would be scrutinized. The utilization review department would probably flag this doctor’s provider number and request more information on a sampling of his or her claims, based almost solely on the volume.

Doctors

Example:

Some other utilization review activities may occur due to the type of services that a doctor may offer. For example, if a cardiologist should suddenly start billing for a large number of incisions and drainage of foot abscesses, this might trigger a review, since that might not be a typical scope of service for this doctor in this locality. The same could be said for a pathologist, triggering a review due to the high volume of wound care or ulcer debridement.

Geographic Variations

Thresholds also vary from locale to locale regarding what triggers an audit. There are consultants who have suggested querying local carriers for medical provider specific information regarding utilization activity to compare against community performance. On the other hand, some Carrier Advisory Committee [CAC] representatives have indicated that this may bring undesirable attention from the Medicare program and trigger an audit.

Assessment

Now that the concept of medical billing normalization has been proposed, and we have some definitional clarity regarding potential variations, consulting professionals suggest obtaining current information with caution.

Conclusion

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Healthcare Fraud versus Healthcare Abuse

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Understanding Definitional Semantics

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Fraud Defined

Fraudmay be defined as any illegal healthcare activity where someone obtains something of value without paying for, or earning it. In healthcare, this usually occurs when someone bills for services not provided by the physician.

Abuse Defined

According to the Dictionary of Health Insurance and Managed Care, healthcare abuse is the activity where someone overuses or misuses services. And, according to the Center for Medicare and Medicaid Services [CMS]:

“although some of the practices may be initially considered to be abusive, rather than fraudulent activities, they may evolve into fraud.”

Example:

In the case of healthcare abuse, this may occur when a physician sees the patient for treatment more times than deemed medically appropriate. If there are reported issues or actions from other sources, such as the NPDB or a medical board, a health insurance program can take that opportunity to review healthcare providers’ activities. Most participation agreements allow for this type of scrutiny.

Assessment

And so, now that a workable definition of healthcare fraud and abuse has been proposed, and we have some definitional clarity, any preliminary billing or invoice review program will usually request a sampling of specific medical records. This may progress to an on-site review of any and all medical records of patients that participate in a CMS program.

These activities can be generated by the plan’s quality assurance, or quality improvement program, and often are tied to the credentialing process for a provider’s participation.

Conclusion

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