I am a huge fan of attorney Knicole Emanuel’s legal blog, and the latest one is a must-read. Audits are nearly universal for wound care and hyperbaric practitioners – the entire alphabet soup is being thrown at us – RAC, UPIC, TPE, CERT, etc. They are supposed to have a “statistical sample” of charts (usually 20 patients), but what I’ve seen them do is to audit 20 hyperbaric treatments in the same patient and call that a “statistical sample.”
For example, let’s say you were missing a hemoglobin A1C in the chart of a patient getting hyperbaric oxygen therapy for a diabetic foot ulcer. If they look at 20 treatments from the SAME patient, that error will be 100%. They then extrapolate the amount of money for paid for that one patient to all the hyperbaric treatments you have provided to all diabetic foot ulcers, and voila! You suddenly own Medicare a million dollars – due to one missing lab test in one patient. As far as I know, no one has yet taken the audit organizations to task about auditing the same hyperbaric patient 20 times for a “statistical sample.” However, Ms. Emanual has won a big case dealing with extrapolation.
In her blog, she discusses the new rules stating that no extrapolation may be run if the error rate is under 50%. That won’t fix the shenanigans of counting the same patient 20 times, but it will help. Check out her blog here:
Medicare Extrapolation Under 50% Error Rate? No Extrapolation ALLOWED!
