MMP’s Protection Assessment Report (P.A.R.) combines current Medicare Fee-for-Service review targets (i.e., MAC, RAC, OIG) with hospital specific paid claims data made possible through a collaboration with RealTime Medicare Data (RTMD). Monthly, our newsletter spotlights current review activities. This month we focus on seven of the recent review results posted by the Supplemental Medicare Review Contractor (SMRC).
Project 01-034 Transforaminal Epidural Injections
Background: 2018 CERT Improper Payment Report noted a 29.1% error rate for this service. Also, a previous SMRC contractor found a claim error rate of 40% with 30% of the claims error being due to no response to documentation request.
- Dates of Service (DOS) Reviewed: July 1, 2018 - June 30, 2019.
- Claims Error Rate: 65%
Common Denial Reasons: Incomplete/insufficient documentation, no response to documentation request, and documentation submitted did not support identification and administration of medication and or dosage limitations.
Project 01-058: Traditional Telehealth
Background: Under COVID-19 waivers and flexibilities, Medicare can pay for office, hospital, and other visits furnished via telehealth across the country and including the patient’s place of residence starting March 6, 2020.
- DOS Reviewed: March 6, 2020 - May 13, 2021
- Claims Error Rate: 88%
Common Denial Reasons: documentation did not support the use of appropriate real-time telecommunication technology and documentation did not support the signs and symptoms to warrant billing an E&M visit.
Project 01-302 Cataract Surgery
Background: This surgery had been a topic of the OIG for many years. They have reviewed surgery in both the outpatient facility and ambulatory surgery center setting. CMS data reflects a potential vulnerability.
- DOS Reviewed: CY 2019
- Claims Error Rate: 51%
Common Denial Reasons: No response to the documentation request, documentation submitted did not support the required documentation needed for cataract surgery, and the documentation did not include a signed physician order or documentation to support intent to order.
Project 01-304 Facet Joint Injections
Background: The OIG has found significant billing errors in this area in the past and an October 2020 OIG report found that due to coverage limitations Medicare improperly paid out $748,555.
- DOS Reviewed: CY 2019
- Claim Error Rate: 92%
Common Denial Reasons: Documentation submitted was insufficient or incomplete. Documentation submitted did not support medical necessity as listed in National and Local Coverage determinations. No response to the documentation request.
Project 01-305 Inpatient Psychiatric Facility
Background: The OIG found on 87% error rate on claims reviewed dated fiscal years 2014 – 2015. A CERT report published in February 2016 and updated in July 2020 highlighted DRG 885 (Psychoses) as the eighth top service with the highest improper payment rate.
- DOS Reviewed: January 16, 2019 through December 31, 2019
- Claim Error Rate: 26%
Common Denial Reasons: documentation submitted lacked evidence that category requirements were met. No response to the documentation request. Documentation submitted did not include the required certifications or recertifications for the inpatient psychiatric stay.
Project 01-308 Outpatient Therapy
Background: The Bipartisan Budget Act (BBA) of 2018 created a medical review (MR) expense threshold of $3,000 or physical therapy (PT) and speech-language pathology (SLP) combined and $3,000 for occupational therapy (OT). The SMRC was directed to perform data analysis on outpatient therapy claims below the 2019 therapy threshold and recommend codes to be selected for review, recommend a sampling strategy, and identify MR strategy for the project.
- DOS Reviewed: CY 2019
- Claim Error Rate: 39%
Common Denial Reasons: No response to the documentation request. Certifications for the Plan of Care (POC) not present. Documentation did not support the initial POC was certified by the physician / NPP. Lack of evidence of delayed certification attempts to obtain the certification. Documentation did not support the units billed.
Project 01-310 Endomyocardial Biopsy with Right Heart Catheterization
Background: Modifier 59 is used to indicate that a provider performed a distinct procedure or service for a beneficiary on the same day as another procedure. Potential misuse of this modifier represents a potential vulnerability and has been featured in work done by the OIG.
- Dates of Service Reviewed: CY 2019
- Claim Error Rate: 60%
Common Denial Reasons: No response to the documentation request. Documentation was not sufficient to support the medical necessity of the procedure performed. Documentation did not support that the procedure was performed.
Moving Forward What Can You Do?
- First, make sure your hospital has a process in place to respond to documentation request from the SMRC,
- Read the entire review results that can be found on the SMRC website (link), and
- Identify services that have a related National or Local Coverage Determination (NCD/LCD) that you are providing at your hospital and share this information with key stakeholders.
