
Understanding Payer Audits With David Vaughn JD, CPC
July 12, 2022
Are you afraid of getting audited by insurance companies or Medicare? Do you get anxious when one of the payers sends you a request to audit 5 of your charts? Have you heard horror stories of the Feds knocking on a physician's door? Don't worry--you are not alone.
But not all audits are created equal.
Today David Vaughn joins me to discuss what you need to know about the different types of payer audits. David is both an attorney and certified professional coder and has been my healthcare attorney for 20+ years. David has been instrumental in helping my practice's billing compliance.
Here are some of the topics we discussed during our conversation:
- the difference between a benign audit and the one you should be worried about
- what to do if you get audited
- what your liability is with regard to coding
- the importance of self-audit
- how denials may give you insight into your audit risk
- the difference between federal payers and private payers
- in-network vs. out-of-network audit risks
If you are in private practice you will not want to miss this episode!
More about David Vaughn: David is one of a limited number of healthcare attorneys in the United States who is also a Certified Professional Coder®, certified by the American Academy of Professional Coders® (“AAPC®”).
David has served on the Legal Advisory Board of the AAPC and has written several coding and compliance books and manuals. He is also a national speaker on the legal implications of billing and coding. He also has a national healthcare law practice, and has represented over 2,000 physicians in approximately 40 states in over 10 physician disciplines. His practice consists of representing providers in federal and state prosecutions, qui tam cases, and Medicare and third-party payer audits. He also conducts audits and provides education to providers.
You can reach David at [email protected].
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00:00:00 Hi, it's Dr. Weitz. Thanks so much for joining me for this episode of the private medical practice academy. I'm so excited to have David born with me today. Now I have to tell you all that David is actually my personal health care attorney, who I have used for the past 20 plus years. And he is remarkable in that he is not only a healthcare attorney,
00:00:23 but he is a certified coder. And so I will tell you firsthand that David is primarily responsible for keeping me and my practice out of trouble. Why is that? Well, because he helped me understand early on that being compliant is 99% of the battle. If not more. And showing that you're attempting to be compliant is really the key. So, David,
00:00:49 thank you so much for joining me this morning. My pleasure. Happy to be here. So I thought today we would just talk about audits because people get docs, get letters saying, oh, we need some number of charts from you or we're auditing you. And I think that a lot of people really have no perspective on what is an audit. What's a good audit.
00:01:15 What's a bad audit. How do I know whether somebody is going to be coming, knocking on my door? So let's start by just, you know, if you could give us an outline of the different audit types and what people should be thinking when they get that letter in the mail. Sure. So there are different levels of audits. And you know,
00:01:33 when I get a call on the client and they say, okay, I've got this letter requesting a chart audit, I have two primary questions. One what's the entity that's asking you for the records. And number two, how many records are they asking you for? And so there's a reason for that. There are some entities that when they ask for an audit,
00:01:57 it's benign. So for example, if you get an audit request from a Medicare, a Medicare advantage plan, typically they are not auditing you for to get money back from you. They're trying to get more money from Medicare because they get paid based on the acuity of the diagnosis code. And so you get these plans all the time. They've, they're trying to make more money for themselves.
00:02:22 And they're auditing you to try to Jack up the diagnosis code that they think should have been put into the 1500 form. And so it's not about you, it's about them trying to get more money for themselves. That's the most benign audit. Probably the second level of audit that I'm not as concerned about is called a cert C E R T audit. Typically this is an entity hired.
00:02:45 It could be the LIG itself. OIG stands for office of inspector general and they might be asking for one or two claims, cause they're doing a nationwide audit regarding a particular issue that they think is a problem around the country. And they want to give a national statistic. I got two claims from a group in California. I got two claims from the New York.
00:03:05 I got two plants from Florida. So they're auditing everybody around the country, but just a little bit. And so any amount of money that you might have to repay on those artists, it's only a couple of claims. So we're not concerned about that. The ones that are more problematic are the ones where they're auditing at least 30 claims or more because if they audit 30 claims or more they can extrapolate.
00:03:28 And just to give you an example, I had a group in Colorado where my client was the number one biller of epidurals in Colorado. And they audited about 30 of his claims and the amount of the deficiency Sandy and the audit was only like $3,000. But when they extrapolated that to the universe of claims and a period of 18 months, they requested reimbursement of $352,000.
00:03:57 So in that case a little bit goes a long way. So you want to know, okay, what's the entity auditing me and how many claims are the audit? So that's the first two things I want to know. The next thing I want to know is is the entity auditing UAE, governmental payer. So, you know, you can get an audit from Humana or blue cross or Cigna or Aetna,
00:04:20 those audits while they are material. And they can result in repayments, a commercial insurer. I, private insurer cannot Sue you under the false claims, act a governmental carrier like Medicare, Medicaid. Tri-Care Champas those governmental entities. If you have false claims under those programs, then the government can Sue you for what used to be $10,000 per false claim. But now with the inflation adjustment act,
00:04:55 the penalties are adjusted for inflation. Believe it or not such that it's now like over $26,000 per false claim. So you want to know, do I have, did I have a government payer that's auditing me or not? So let me just stop there. And then you can ask some follow-up questions. So what exactly is a false claim? Okay. So a fault claim actually has a definition.
00:05:19 So there's a false claims act, a statute that has passed that in the United States code. And it essentially says that if you know, a claim is false and you file it, then you are liable for these penalties. You're liable for three times the amount that you received plus about $26,000 per false claim. Now the initial response for most providers as well,
00:05:46 I didn't know is false, but knowing has a definition that you would not anticipate in the federal rules. So knowledge under the false claims act means one of three things. One, you actually knew it was false. Okay, well that wouldn't be a crime and that would be healthcare fraud. But number two, it's, what's called deliberate ignorance. You stuck your head in the sand and you didn't want to know.
00:06:12 Or number three is what we call reckless disregard. Most people would think of that as gross negligence. So I'll give you the primary example the government uses. So what you're telling me that you build this particular CPT code and you didn't know that the CPT code was not correct. You picked the wrong CPT code. Well, you've got a CPT code in your office and if you don't,
00:06:32 you should have. And if, if you have one, then you are attributed with the knowledge and the CPT code, oh, you use the wrong diagnosis. Well, you got an ICD 10 code in your office. And that knowledge in that code is imputed to you. Whether you read it or not is not material you are assigned with that knowledge,
00:06:50 whether you actually looked at it or not. So when you bill, you're supposed to do your homework and know whether you're billing correctly or not. Okay. But here in lies the problem, because I'm sure that a lot of people listening to this are probably sitting on edge now going, oh, wait, I have a biller, I have a billing service.
00:07:12 I outsource this. Or maybe I have a biller in my office. I just complete the note. And supposedly, you know, even if I choose the ICD 10, even if I choose to CPT code, somebody is looking at this to make sure that it's right before it goes out. So how am I the provider really liable for this? Okay.
00:07:37 So that's certainly a good question. And the answer is that because your name is on the 1500 form and you're the one getting the check. You're the one that's liable. That's, that's the simple answer. And that's how the feds look at it. Now, is it possible that you might be able to Sue your billing company, your outside billing company?
00:07:53 Yeah. It's possible that you could Sue them. They're the ones that screwed up, but the feds are come looking at you. The reimbursement is going to come from you, not them. And if it's your employee, well, there's the doctrine of vicarious liability. Just like a parent is liable for their child. And employer is liable for the actual their employee.
00:08:12 And if those acts are wrong, then the employer is still liable for it. Civilly, not criminally. So if your builder does something criminally wrong, well, you're not going to go to jail for that. If you didn't have anything to do with it. But civilly, yes. If your employee picked the wrong CPT code, a thousand times, you're responsible for any,
00:08:30 you know, overbilling that occurred. So, you know, one of the things that docs are always talking about is we don't actually ever learn how to code. So w w what do you tell clients in terms of how do they even go about trying to learn how to code? Because this business of, you know, especially they just changed the ENM rules a year ago.
00:08:55 You know, th the modifiers modifiers are always changing. What's bundled is always changing. How does the doc learn this? Well, that's, I don't know that they always do learn it. Okay. Yeah. I have a couple of pieces of advice of how physicians should become familiar with coding. For most physicians, there's a finite set of CPT codes that apply to their practice.
00:09:22 So, you know, not everybody has to look at the whole CPT code. There's like 6,500 codes in the CPT code, but if you're an orthopedist, okay, well, there's a certain number of CPT codes that apply to you. If you're paying back, you've only got a certain number of codes, anesthesiologist, same thing. Each discipline has a certain limited number of codes that apply to them.
00:09:40 Learn those codes, ENM codes. Well, it's more about what's documented in your note and those coding rules rules have changed. It's not so much about the code as it is the documentation. And I think probably the, the most important thing that I think in talking to my clients, that they have found helpful. They've hired certified coders. So I'm an attorney,
00:10:02 but I'm also a certified coder. And to be a certified coder, you've got to code for two years, you got to take a test and pass it. You got to have 18 hours of continuing education units each year to maintain your certification. So having somebody in your office that can say, wait a minute, that's not right. Or I've read something that says that this is the wrong code,
00:10:22 or you're not documenting this correctly. That is invaluable. So that's the first thing, are you certified coder that knows what they're doing. Number two, and send your charts out to be audited by somebody who knows what they're doing in your discipline. So find somebody that's an expert in your discipline. Like for me, you know, I represent pain, physician groups,
00:10:43 orthopedic groups, anesthesiologists, and we audit at least 50 claims for nearly all of our clients. Every single year. It's a prophylactic audit. It basically tells them, yeah, you might have the right code, but there's a local coverage determination. What's called an LCD on this particular service that you're providing. And you're not documenting according to what the LCD says,
00:11:04 are you use the wrong code or, Hey, you using a new modality here that the government considers is investigational. And that means it's not medically necessary. And that means, even though you've got the right code, they're not going to pay for it. So you shouldn't be billing that code because, you know, you should be getting an ABN. So think certified coder,
00:11:24 learning the codes in your code, set, you know, outsourcing your claims to be audited once a year. All of those are grateful. The lactic measures to keep you safe. Well, and I'll be the first one to attest to that because you have audited my charts every year. And you know, if you recall, we had a doc who was overcoding.
00:11:46 We recognized that he was overcoding dealt with it by actually a counseling, him documenting that we counseled him and then returning money to an insurance company and saying, we did this audit ourselves. And this is what we found. And here's your money back. And, you know, I think the thing everybody is thinking to themselves, wait, wait, wait,
00:12:09 I have to give money back. Well, it's a lot less painful to give money back when nobody's asking you for it. Then when the number is three times that size after they've come in knocking. And not only that, when I look at paying money back and I've done this hundreds of times, and, and, and typically here's the question I get from my client.
00:12:32 Well, by paying money back, they're going to aren't they going to broaden the audit and come after me for more, for more money? Actually, the answer is no. Think about this. There's an old saying we don't bite the hand that feeds you. So if we have people paying money back to the government and the government were to audit all those people,
00:12:54 paying money back, everybody was stopped paying money back. So that's actually not the case. And I also 25 years, I've been doing this. I may have had one question from the entity that we paid money back to, and I've never had anybody that's been audited. The second thing that's good about paying money back is that man, now I can argue that my client's in good faith.
00:13:18 If somebody says, Hey, your, your client, they over-billed us. And we think they did it prominently. Well, that's not the case because I got a track record of paying money back when nobody audited them. So if they're such a good citizen, that they would pay you money back without you knocking on their door, without you sending them a letter without you asking for the money,
00:13:37 then there's no way you're going to be able to prove that my guy's a bad guy. So I hope that I think it helps to insulate you when you pay money back. I would agree with that. So one of the things that people are always afraid of, and you and I have experienced this in our community is the knock on the door. And the feds are at your door.
00:13:56 What do you, or, or it may not be the feds. It may be somebody else. What do you do in that case? I mean, it's pretty benign. If you get that letter and to your point, it's only a few charts, but I think everybody is afraid of what happens. If it's the big deal, what, what should we do?
00:14:14 Okay. So there's two kind of knocks on your door. There's the knock where the FBI is investigating you. That knock is typically at six o'clock at night. When you're home, when you're least expecting it, you are your employees. And it's typically two people and they want to come in. They are, they don't announce themselves. So you can't prepare for it as a complete shock.
00:14:38 Okay? But you are entitled as a United States citizen to refuse them entry into your house unless they have the second kind of knock. Second kind of knock is a search warrant. So if there's a search warrant, there's typically going to be a swarm of FBI agents and they're going to have guns. And sometimes the guns will be drawn. Even with health care providers,
00:15:00 as absurd as that may be. If they show up with a search warrant, you have to let them in, you get a copy of the search warrant and all they can do is search and take the things in that search warrant. That search warrant is followed with an order that the judge signed, allowing them to come into your premises and take the items on that list.
00:15:20 If you get that kind of a knock, that is something to be worried about because a judge in our country cannot issue an order for a search warrant, unless there is probable cause to believe a crime has been committed. So if you get that, you better be calling your lawyer as quickly as you can. If you get the other knock on your door where there's no search warrant and people want to talk to you,
00:15:41 you have a right to say, no, I I'm happy to talk to you later, but I got to get my lawyer. And then we'll talk about talking to you. So you don't have to let them into your house. You don't have to say a word that you're right as an American citizen. So hold on for a second. They're going to show up at my house or they're going to show up at my office.
00:15:59 No, they're going to show what your house that's there. Okay. Could they show up at your office? Yes. But when they're typically investigating, they like to catch people by surprise and they will show up, you know, at, at her house. Now, usually if they're after a big fish, so let's say they're for you. Okay.
00:16:18 They're going to show up at your employee's house at six o'clock. And they're going to ask your employee about you, because they're going to figure that they're going to be able to intimidate, you know, little Suzie, who's a receptionist, or who's the biller, and she's going to be freaked out. She's going to let them in. And she's going to answer all their questions that they have about you,
00:16:35 but not going to start with you. So if you, if you learn that your employees are being interviewed by the feds, and that means in all likelihood, they're looking for a bigger fish. They're not looking really to go after the employee. Very interesting. And what about, you know, the private insurers? Do they ever come, you know,
00:16:53 knocking or they just asked for more and more charts? Yeah. They typically don't come knocking cause they have no legal authority whatsoever. They have no ability to prosecute you. They can Sue you, but they can't Sue you for penalties. They can't Sue you for $26,000 per false claim. So the answer is no, they typically don't knock on your door.
00:17:12 It's only government people to knock on your door. And so another follow-up question to that is, let's say I am audited by insurance company X, and I have to give them back money. Do they? And you know, or let's say it's Medicare and you probably will recognize the doc that I'm thinking about. Let's say I get audited by Medicare. I have to give Medicare a bunch of money.
00:17:37 Does Medicare tell blue cross or Humana or Cigna and, and tip off all the other insurance companies that maybe I'm doing something that, you know, they can recoup money or each one is siloed independently. It depends on whether it's criminal or civil. If it's criminal, they will definitely get blue cross involved. As a matter of fact, blue cross refers more people to the feds.
00:18:03 At least in my opinion, the way I've seen it than just about any other insurer blue cross, because it's probably the biggest insurer in the country. It has a special investigative unit S I U. And so if they feel like something criminal has happened, they'll turn that case over to the feds and believe it or not, even though the feds cannot Sue you for the money that you overbuild blue cross,
00:18:31 they can indict you for healthcare fraud that you did to blue cross or any other commercial carrier. So the way the statute works is that healthcare fraud is defaulting. Any benefit payer. It doesn't matter who it is. Cigna, Aetna, Humana, doesn't matter if it's fraud true fraud, you knew. And by the way, people throw around the F-word the fraud word way too loosely in order to prove fraud,
00:18:54 the government's got approved that you knew about it. You really knew about it and you did it anyway. So that's, that's not that you know, it's not that easy to prove, but commercial insurance carriers typically might turn people into the feds, but the feds don't call up blue cross and say, Hey, they overbilled me for $50,000. Why don't you guys check and see if they overbuild you too?
00:19:18 No. Okay. So couple more questions. What exactly is a RAC audit? So RAC is an acronym stands for recovery audit contractor. So RAC is somebody that will audit your charts. They have three to four years to go back and look at your claims. And if they feel like that you have overbuild, then they will audit your claims. Now racks are unique in that they get paid a percentage of what they find.
00:19:50 So they'll, there's a process by which the government will send out a proposal. You want to be , okay? Tell me how much you're going to charge me. And typically the rack makes between nine to 11% of whatever they recover. So the bad news is they're incentivized to find something wrong, which is why I've always objected to having a RAC audit,
00:20:08 because you think they're going to knock on my door and they're going to look at my charge and they're going to come away saying that I did not do anything wrong. No, they're always going to find something wrong because they get paid for that. So I think that's a conflict of interest. They try to mitigate that conflict of interest by saying, oh,
00:20:23 but we also look for underbuilt charges as well. Well, sorry, but you know, I call them BS on that one, but here's the thing about the RAC audit that's unique and different than other auditors. They do. What's called data mining. So they are looking for low hanging fruit. They're typically not the one that is looking for a complex that they've got to jump in and audit,
00:20:48 you know, down into the nitty gritty to find something. Nope, here's what they would do. Give you a perfect example in the pain world. So in the pain world, you can do say five Fossette injections in a year. So what they do is they go into their data and they look to see if you did six or seven. They're not auditing your charts.
00:21:09 I don't even look at your charts. They're just saying, did you do six or seven? So the limits four or five, did you do more than the limit? That's the kind of stuff that they do. So whenever I see my client audited by a RAC auditor, I know that they're looking for low hanging fruit and lots of times they haven't even audited the charts.
00:21:25 My client will say, gee, baby, they didn't even ask me for any charts. How is it that they're asking me for money back? Well, because they did that. I'm mining based on the LCDs and you did something that's contrary to the LCD. So they can just look and see, you know, by looking to see the codes that you build.
00:21:42 So couple of things for everybody who's listening and doesn't know exactly what an LCD is or the details about it. There is actually a podcast episode. So go into the private medical practice academy and book for local carrier determinations and what it is and why it's important to you for a detailed description of it. But let's come back and talk about LCDs and, and actually the number of anything,
00:22:09 whether it's for sets or the number of times, you can do a urine drug screen or the number of times you can do w name, the procedure or a name, the name of the test. How do people actually find that out? Because I think that there are a lot of folks who get denials for things and it's because they're doing whatever it is too often.
00:22:34 Now, I think, first of all, and tell me if you agree with this, if you're getting a bunch of denials for something, because you're doing it too often, then you actually are setting yourself up to be audited for doing that thing too often. Is that a fair statement? Yeah, that's a correct statement. The Fed's track, you know,
00:22:54 whether you're an outlier or not, most of the people listening to this podcast may have received a letter from Medicare saying, this is, this is the percentage of time that you're doing this. And this is what the peers, your peers are in the state. And this is what your peers are in the country, as far as their proclivity for billing,
00:23:11 this particular thing. And you're out of whack. So you're an outlier warning shot across the bow. We're going to audit, you have discontinues. So yeah. Now go into the LCD. I do want to stress this just briefly, even though you've got another podcast on it, that LCD LCD's are only adopted for things that have been abused. They're not adopted for things that are garden variety,
00:23:34 that nobody, you know, abuses. So perfect example, you're in drug test flow, you know, pain doc started creating all these complex labs so they could do their own urine drug test. All of a sudden Medicare went from paying a hundred dollars to a billion dollars, you know, and you're in drug test. So they track that automatically. And then they publish an LCD that says,
00:23:55 okay, these are the things that you have to have in order to do a urine drug test, same thing with certain injections. You know, these are the things that you have to do in order to do this injection. So go to your Medicare website, look for the major procedures you do determine if those procedures have an LCD. That is what auditors will use as a checklist to determine when they audit you.
00:24:18 Did you do each of them, the things in the LCD. So let me ask you a question about, you know, denials. Do you think that the, if you see that you get a certain number of denials for X, that that is also a shot across the bow, like, is that a warning sign or denials or just something of noxious that insurance companies are doing?
00:24:49 I don't think that denials drive audits because you didn't get paid audits are driven by recovering money. So if you didn't get any money because you got denied, it's not likely they're going to audit you for all the denials that they did. They're going to audit you for the things you got paid for. No, I didn't mean that you're going to get audited for the denials.
00:25:10 Obviously, if you don't get paid, they're not going to audit you. What I meant was if you keep trying to do a certain procedure and you keep getting denied for it. Okay. But there are some insurances that are paying you for it. Okay. Should that be a red flag to you that this particular procedure for example is on somebody's red flag list?
00:25:35 That's a great question. So that's especially true with new procedures. So for example, right now, you know, I've got clients, they'll call me once a month. Hey, I got a vendor knocking on my door, they've got this new procedure. It's minimally invasive. And it pays me. Wow. I mean, it pays me like crazy.
00:25:52 I want to do this procedure. And so can you research and make sure I can do it? So we'll research it and we'll find that, you know, blue cross of Illinois got a policy, but blue cross of New York doesn't. And so the blue cross in Illinois, if you submit that code, they're denying it. But blue cross in New York has never even looked at it.
00:26:08 It hasn't examined it and they're paying it because they don't have an edit yet. But at some 0.3 years down the road, they do look at it. And then they come back and say, Hey, we've determined that this was not medically necessary for the past three years. Now, pay us all this money back. So do not go into a new modality unless you've had that research and determine whether or not there are payers out there that have taken the position that it's new,
00:26:31 there's not sufficient, you know, randomized studies that prove it's efficacious and that it's medically necessary because they will go back retroactively and grab that money back. Absolutely Well, especially for procedure where or where they're trying the vendors trying to sell you a very expensive piece of equipment. You know, that that certainly is an issue. So, you know, in terms of insurance and audits,
00:27:02 one of you know, the latest, greatest idea, which kind of entertains me is people who want to be out of network, okay. Doctors who want to be out of network, because they're tired of dealing with the insurance companies or doctors who want to have a cash pay practice, where they charge the patient cash. And then the patient turns around and submits that bill to the insurance company to get whatever out of network benefits,
00:27:30 they were going to get 10, the doctor who's out of network, be audited. They can be. But man, that's a, that's a tough, a tough claim for the insurance company to win, to be honest about it, because you know, if you're in network, what does that mean? Legally? It means you signed a contract with that insurer and you agreed in that contract to abide by not only what's in the contract,
00:27:55 but what's in the provider manual, that's online, it's in every single network contract. So now you've got a contract that binds you to all their medical policies. Well, what if you didn't sign that contract? What if you're not in network? Well, you didn't agree to anything. And so the insurance company can't say, well, he, you got to follow our policies.
00:28:12 No, I didn't agree to your policies. So then it comes down and you may remember this because we had a work comp case. You and I did what, where the issue was, what is, you know, the industry standard, what's UCR usual, customary and reasonable. So if you don't have a contract, that means what, when it goes to court,
00:28:32 the judges are going to say, okay, what's your usual customary and reasonable Mr. Insurance company. And you're going to have the burden to prove they have the burden to prove that your charges are not reasonable and necessary. And that's a tough burden. So, you know, yes, it's cleaner in an audit if you're not in network, much harder for the insurance company,
00:28:51 but then, you know, an insurance company might be sending your checks to the patient. And so it's harder to get paid if you're out of network, Right? No, no, no, no. I was not advocating for being at a network. I think being at a network comes with its own host of headaches, but I know that one of the things that people think sometimes is that indeed,
00:29:11 you know, if I'm out of network, then I don't have to deal with the potential for being audited. And clearly what you're saying is that's a correct assumption, but you have to weigh that the risk of an audit and being in network versus the ease of getting paid. So Yeah, I get, look, I'll give you a perfect example. A few years ago in Florida,
00:29:34 there was an insurance company that sued one of my clients that was out of network. It was an anesthesia client. And for those people that don't that anesthesia billing you can build, what's called a medically directed claim where the physician bills, half the claim and the CRNs bills have to claim. And so the theory is that when you combine 50% for the doc and 50% for the nurse,
00:29:55 you get a hundred percent for the claim. Well, this client billed a hundred percent for the doc and a hundred percent for the CRN and got paid 200% for the claim. And so one day the insurance company woke up and did an audit and said, we're going to pay you 200% when we should have been paying you a hundred percent, give us a hundred percent back.
00:30:12 And so we had to go to trial on this case because that client was out of network. So then the issue became for the judge. Well, what's usual customary and read them. So do you have a sense of the percentage of audits? So for an average practice, you know, what's their, what, what's actually their risk of being audited,
00:30:34 both. You know, it sounds like the benign audit, you know, the Medicare advantage programs I know happen all the time. So we'll take that out of the equation. But other than that, you know, they, the, the GI may actually have to pay somebody some money, risk of audits. How often does that actually happen? It really depends on the practice in which you're involved.
00:31:01 What's your discipline. So, you know, I primarily deal with three disciplines and of those three disciplines, you know, there's one of those disciplines. They are getting hammered every month. I kid you not, there is a different auditor knocking on their door, asking for records, you know, especially ancillary services, right? Because you've got your core services,
00:31:22 that's in the CPT code. And then you've got these ancillary services, you know, maybe it's UDT, maybe it's back braces, you know, maybe it's PT. So maybe it's radiology, all these ancillary services. The more that you have, the more likely that you're going to get audited for some of the other disciplines I represent it's once in a blue moon.
00:31:38 Okay. So what you're telling us is all of my pain docs out there should not be surprised if they get audited Every month. I mean, I'm not kidding because you got DME audits, you've got UDT audits, you've got just, you know, ENL, new audits. Yeah. It's every month. So, you know, and this is probably more of a stark and anti-kickback,
00:32:01 and depends on the state that you live in. And I'm sure there's a lot more nuance, but I'm going to ask the question anyway. And that is in that case, is it advisable to silo off each of your entities separately? So like for example, have a DME company have this company have that company so that you're not exposing all of your practice.
00:32:27 Yeah. I think that's going to be difficult because you know, stark requires, you know, under the in-office ancillary services, exception that that'd be done in your office as part of your practice. So the only carve out that I know of that you could put, set up a separate company would be the UDT. You could have a lab that you owned separately,
00:32:51 but it still has to be billed a hundred percent in the company's name. And that has to be owned a hundred percent by the medical practice. So the answer is no, I don't think it does you any good. Okay. And that was my assumption, but I know that that's one of the questions that people always have. So tell us, before I let you go tell people how they can find you,
00:33:12 because I cannot, how valuable auditing having you or somebody liked you audit the charts. Preemptively is I know, you know, to your point about the head in the sand, it is very easy to have your head in the sand. And there is nothing more embarrassing than when David comes back with this stack of charts and says, especially, even if you have issues,
00:33:38 Hey, you could do this better. Or your documentation should be X, Y, and Z, or, Hey, you have a doc in your practice. Who's doing blah, blah, blah, blah, blah. But in the end, it is far less embarrassing to have David or somebody that is preemptively auditing your charts, tell you what your problems are.
00:33:59 So you have an opportunity to fix them then to find out by surprise, because the worst thing in the medical practice, when you are running a medical practice, are those surprises that you, you are totally unprepared for. So David tell us how we can find you. Okay. So my email that's the best way to get in touch with me [email protected].
00:34:24 So LA like the abbreviation for [email protected]. I have four certified coders, including myself that we audit our claims. And one of them was an attorney. The other two certified coders have been certified for awhile. Holly has been with me for 15 years. I've been a certified coder since 1999. So we've been around the block and yeah, I think we could do a pretty good job on telling you where your holes are that need to be fixed Well.
00:34:53 And I think the reality is, is that it is very hard to practice medicine and not have those holes. And so I think instead of thinking, oh, my practice is doing great. It's a whole lot easier to find the holes that have somebody tell you the holes and fix them then to keep thinking I have no holes. So I cannot thank you enough for joining me today.
00:35:17 It's been great. I've enjoyed it. Thank you for having, Thanks for joining me. Please be sure to sign up for my newsletter below, I'll be sending you tips on how to start a practice, grow a practice, and then add multiple services so that you can maximize your revenue.

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