Featured coffee – Espresso Hot Chocolate
A colleague requested me to meet with her personal physician, who expressed concerns about his low reimbursement.
As I shared with you in OIG Exclusions List and Corporate Integrity Agreements, I routinely check potential clients for exclusions or integrity agreements. This physician was not under a Corporate Integrity Agreement, and he was not included on the OIG List of Excluded Individuals/Entities (LEIE).
The meeting went very well, and we agreed on the terms for the contract. I told the physician I would send him the service contract for his signature, and then the work would begin.
The physician’s office manager forwarded the records to be reviewed, and one of the records was my colleague’s. It’s not unusual to receive medical records of someone you know. That’s why patient privacy is so important. The usual routine is to NOT code a record of someone you know and just pass the document on to another coder. When auditing, explain the conflict and request another record; however, the more significant conflict for me was the date of service for my colleague’s record was the date that she went with me to do the introduction. She was not seen as a patient that day!
The physician’s documentation was virtually non-existent. None of the “records” supported the services that were billed to the payors. I made the decision to not continue the audit, and I didn’t even send the physician an invoice, and I’ll explain why.
The red flag for me was that he created an encounter note for a patient (my colleague) for services that he did not perform. Clearly, he didn’t know his office manager would include that note for auditing, but my instinct was that this was not an isolated case.
Even if the rest of the documentation “supported” the services billed, there was a reasonable probability that the services were not actually performed either.
Fast forward a couple of years. This physician was indicted in a multi-million dollar fraud scheme. He was charged with submitting claims and receiving payments for procedures that were not performed, and falsifying medical records to cover up the scheme.
Disclaimer: I did not report him. I only had one false medical record (one date of service) with proof that the service was not performed, and my gut instinct.