Attorney Knicole Emauel’s recent blog post encourages health care businesses to perform a self audit before the real auditors come knocking. Kathleen Schaum talked about this in the excellent series of interviews we did about how to keep your payments. The things Kathleen recommended are echoed by attorney Emanuel. Here’s a brief excerpt from Ms. Emanual’s blog:
“Now more so than ever, putting your own facility through a thorough self-audit is imperative. You need to understand the policy changes pertinent to your health care service type and dates the changes occurred and when applicable. Before the “REAL” auditors come knocking on your facility’s door, prepare yourself. Consider hiring an attorney or medical compliance expert to conduct the self audit.
The next step in performing a self-audit is for the practice or organization to select a category of service to review. If the practice or organization provides multiple types of services, the focus should be on one category, such as office visits, for review. When reviewing office visit services, the Current Procedural Terminology (CPT) codes applicable to telehealth visits include, but are not limited to, Office or Other Outpatient Services (99201-99205 [new patient] and 99211-99215 [established patient]) and Non-Face-to-Face Telephone Services (99441-99443 [practitioners who may report E/M services] and 98966-98968 [practitioners who cannot bill independently]). Practitioners who cannot bill independently are qualified non-physician health care professionals, such as social workers, clinical psychologists, and certain therapists. Please note, CPT code 99201 was deleted effective January 1, 2021.”
I agree that a self-audit is a miserable “gift” to give yourself, but a real audit is a gift that just keeps on giving when you are not prepared.