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NGS Announces Prepayment Audits of Exam Code CPT 99214

On April 17, 2017, National Governmental Services (NGS), the Medicare Administrative Contractor (MAC) for Jurisdiction JK announced that they were initiating prepayment audits related to CPT exam code 99214 for all providers in MA, CT, and NY – not just those in eye care.  Because this is a prepayment audit, the MAC will ask for records and then audit the services before issuing payment.  The NGS announcement makes the following points:

  • A recent analysis of data indicated CPT code 99214 continues to be one of the top contributors to the CERT error rate, and it has the highest CERT projected errors within the E&M services.
  • The primary focus of the audit is to better identify common billing errors, develop educational efforts, and prevent improper payments for CPT code 99214.
  • Request for records are automatically generated …
  • [It is] only necessary to submit the documentation for the specific date of service notated in the ADR. The supporting documentation would include … progress notes, orders, medication records, procedure/operative reports, relevant diagnostic/operative reports, or documentation of time that would assist in supporting the service(s) submitted.
  • Responses should be sent within 30 days per CMS guidelines.
  • All services ordered or rendered to Medicare beneficiaries must be signed … guidelines regarding handwritten or electronic signatures … are described in MLN Matters article MM8219

In our experience, prepayment audits on this subject may occasionally spread to other states or MACs soon, or they may wait until the results of the NGS results are posted before initiating them.

Your best defense is to be aware of and use proper coding rules and principles.  If you need assistance with proper documentation and coding, Corcoran Consulting Group can help.  You can also get and use our new App, Corcoran 24/7 via one of the links below –it’s free.

 

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