Bounced Check

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As independent contractors, we are always moving on to the next contract.  Most of my work comes from referrals or repeat business.  I learned a valuable lesson years ago about contracting with new clients.

I subcontracted work from a coding contractor, and the agreement was my invoices would be paid 30 days after receipt (standard protocol in the industry).  I submitted my first invoice and waited 30 days for payment.  It was a long-term contract, so I was still working and generating the next invoice.

I received payment for the previous month’s work and deposited the check.  A few days later, I received a call from the owner of the company.  The check was returned for insufficient funds.  She apologized and told me that she could give me another check, or she could do a wire transfer.  That was the first and last time that I experienced a returned check from a client.

Because of this experience, I never deposit the first check from a new client.  I always go to the bank that it’s written on, cash the check, then deposit the cash into my account.

 

All Money Is Not Good Money

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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.

 

 

 

No RVUs For You

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I was requested to perform an audit for a large hospital-based General Surgery group because their relative value units (RVUs) were consistently low.  The group received bonuses based upon RVUs, and the department chief wanted to identify opportunities to increase their RVUs.

RVUs for surgical procedures were at or above goals each month, but I noticed the surgeons were not documenting post-operative visits.  Except for visits for conditions not related to the surgery, or surgical complications that require return trips to the operating room, post-operative services are not paid. Still, quality of care requires that post-operative services are performed.  This facility assigned RVUs for these services, but the providers were not documenting the services. BINGO!

I met with the chief, and we focused on the evaluation and management services.  According to the chief, the Internal Medicine department admitted and discharged their surgical patients, and provided post-operative services while patients were in the hospital.  I asked, “Why?” If it was the hospital’s policy, ok, but if not, why was internal medicine getting their RVUs?

The chief made calls and found out that the former department chief had made arrangements with Internal Medicine to have that department do the evaluation and management services.  That arrangement was terminated that day.