07/23/2020    Paul Kesselman, DPM

CMS to Reinstitute Audits

CMS recently announced that it will be restarting
its pre and post audits, regardless of the state
of the Public Health Emergency (PHE) on August 3
2020.

While all parties involved in coding and
compliance have always advised strictly adhering
to proper documentation and coding, the break in
the audit process was never intended as an excuse
to become lax regarding proper charting and
billing. The audit lapse by CMS and its
contractors was intended as a means only to
provide providers with some relief, allowing
medical practices more time to deal with COVID
related matters and direct patient care or to
relieve providers who had to close their doors
and/or furlough staff due to COVID.

This announcement unfortunately comes at a time
when the PHE is actually worse in many states
than it was back in March. Staff in certain
locations are pressed now more as COVID ramps up
in twenty states and is far worse than four
months ago. In other areas, such as the
Northeast, where COVID, at least for now, has
seen a sharp downturn, staff and providers are
dealing with a backlog of patients, who went
unseen for four or more months.

Thus this announcement will result in providers
and staff being at times pushed to or beyond
their limits to deal with all the issues involved
in running a medical or supplier practice, in
addition to the issues previously addressed.

Nevertheless, be prepared for a backlog of audits
both in the form of prepayment TPE letters (which
are supposed to be more educational) from your
MAC; or a post-payment audit from the SMRC or
RAC. It should be noted that the RAC has been
lobbying for a restart of their audit process for
months. This simply because their financial
lifeline is based on a percentage basis of what
they recoup from you.

Paul Kesselman, DPM, Oceanside, NY

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