Why Live Coding Auditors?
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Maybe. Maybe Not!

With a greater emphasis on electronic medical records (EMR), more and more physicians and health care providers are relying on the EMR to perform their coding for them.

It may seem an obvious choice for providers who have made a substantial investment in technology and hope to recoup some of that by having that technology code for their practices however greater use has resulted in some disturbing findings when it comes to coding through the EMR.

What you need to consider...

  • Planning for and implementing and EMR should take between 6 to 12 months. After that full implementation can take another 12 to 18 months. EMR vendors want to make a sale, and they often under-estimate the planning and training that any one specific practice needs.

    Without planning and implementation specific to YOUR practice and your specialty, your practice may be relying on standard templates, or templates that were hastily set-up and not appropriately tested against a “real live coder”.
  • Studies have shown that when an EMR system’s documentation features are improperly used, you actually increase your risk of an audit.

    The risks of audit increase due to systems that are set-up with “cut and paste” options for documentation, systems that automatically assign a “negative finding” to and ROS, PFSH or HPI box that is not completed, and of course systems that auto-fill any areas of the template.

    According to an article in Part B News, the “proliferation” of EMR systems “allows easier documentation,” thereby justifying higher E/M levels. It is likely Medicare may target these code levels for an audit sooner rather than later.
  • Many vendors will claim that the EMR will ‘code’ for you. They may also infer or even outright claim that EMR coding will help your practice make more money. Remember…”If it sounds too good to be true, it probably is!”

    Be sure that you and your practice colleagues understand the logic behind your EMR’s code calculator. Often the algorithm for the medical decision-making (MDM) component of the E & M coder is simply incorrect, resulting in suggested code levels that don’t match the documentation and can put your practice at risk.

    Check out your specific specialty practice management journals. In each one, you will find reports of practices who have found that their high level E & M codes increased after implementation of their EMR.

    In some cases, this shift in the standard bell curve has resulted in insurance audits with findings showing that the codes were too high for the documentation in the EMR. In other cases, practices have been more pro-active in light of these E & M code “improvements” and they decided on an audit in which the inaccuracies were confirmed, allowing the practice to have their billers override the suggested code(s) and bill the correct code.

                           OIG 2012 Work Plan Includes Review of EMR/EHR

The 2012 US OIG Work Plan includes direction to review EMR/EHR systems due to concerns over system up code selection, cloning of patient data on subsequent visits, and auto population or “auto fill” features. Audits have shown electronic charts with data pulled forward without updates by the physician, histories auto populated without evidence the work was actually performed and charts where EMR/EHR systems have up coded based on history and exam elements without the proper medical necessity. 99214 is currently the most audited code due to this systematic up coding.