Eight medical coding mistakes that could be seen as fraud or abuse

Unfortunate cases of fraudulent or abusive medical billing practices have been highlighted by the Government through auditor reports. One deserves to be paid for providing the medical care but it is essential that there are no improper billing practices. The American Medical Association (AMA) offers 8 tips on avoiding compliance problems with medical coding and billing, which are in the sights of federal prosecutors rooting out abuses.

With respect to the medical coding errors, they fall into the broad categories of “fraud” and “abuse.”

Fraud represents intentional misrepresentation and abuse refers “the falsification was an innocent mistake, but nonetheless representative,” according to the AMA’s Principles of CPT® Coding, ninth edition. An example of abuse could involve coding “for a more complex service that was performed due to a misunderstanding of the coding system,” the text notes.

The AMA has a number of resources to help accurately with bill procedures and services with Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System codes.

Most common compliance problems to avoid in medical coding:

1. Unbundling codes-When there is a single code available that captures payment for the component parts of a procedure, that is what should be used. Unbundling refers to using multiple CPT codes for those parts of the procedure, either due to misunderstanding or in an effort to increase payment.

2.Upcoding- Example: One meets for a few minutes with a patient about a routine question, but the coder bills for a full exam lasting 45 minutes. That is a no-no, though often cases of upcoding are not so blatant.

But sometimes they are, and the consequences can be severe. One psychiatrist was fined $400,000 and permanently excluded from taking part in Medicare and Medicaid in part due to upcoding. He billed for 30- or 60-minute face-to-face sessions with patients when, in reality, he was only meeting with patients for 15 minutes each to do medication checks.

3. Failing to check National Correct Coding Initiative (NCCI) edits when reporting multiple codes- The Centers for Medicare & Medicaid Services developed the NCCI to help ensure correct coding methods were followed and avoid inappropriate payments for Medicare Part B claims. These are automated prepayment edits that are “reached by analyzing every pair of codes billed for the same patient on the same service date by the same provider to see if an edit exists in the NCCI,” the AMA’s text notes. “If there is an NCCI edit, one of the codes is denied.”

Example: You bill for a lesion excision and skin repair on a single service date. But CPT coding guidelines say simple repairs are included in the excision codes, so separately coding the repair would be wrong and generate an NCCI edit. But if the repair was performed on a different site from where the lesion was removed, it is OK to bill for both and append a modifier to let the payer know the procedure was indeed separate from the excision.

4. Failing to append the appropriate modifiers, or appending inappropriate modifiers-Related to case outlined above, this could involve reporting modifier 50– a bilateral procedure to a procedure code that already includes bilateral service.

5. Improper reporting of injection codes- One code for the entire session during which the injections take place should only be reported instead of multiple units of a code.

6.Reporting unlisted codes without documentation - If an unlisted code is used to bill for a service, then it should be properly documented.

7. Overusing modifier 22–increased procedural services. One must include proper documentation to explain why the procedure requires more work than usual.

Example: You excise a lesion located in the crease of the neck of a very obese patient. The obesity makes the excision more difficult. In such a case, appending the modifier 22 to the code used to report the removal can indicate the complexity of the service.

8.Improper reporting of the infusion and hydration codes, which are time-based-Good documentation of the start and stop times are essential for medical coders to properly bill for these services. And then there are wrinkles involving services that are provided over two days of service.

Example: A continuous intravenous hydration is given from 11 p.m. to 2 a.m. In that case, instead of continuous infusion, the two administrations should be reported separately as initial (96374) and sequential (96376).

For reference log on to https://wire.ama-assn.org/practice-management/8-medical-coding-mistakes-could-cost-you