Even in today’s environment which
places a high value on compliance and
accuracy, I encounter billing practices that
cause potential concerns. Systems and
policies/procedures that were established
years ago may still be in place because “if
it isn’t broke, don’t fix it.” And, quite
frankly, there are more pressing issues to
deal with from an administrative perspective. Following are some examples of billing procedures that may contribute to
incorrect billing practices. These statements are not meant to serve as a condemnation of these practices but rather to
highlight and focus on the potential areas
of concern so that you can ensure compliance within your organization.
• • Billing•based•on•the•order. If you are billing based on what was ordered instead of
what was performed you may have a
problem with some procedure notes not
matching the submitted CPT® procedure
code(s). Granted, you should only be performing what was ordered, but what happens when the technologist obtains a
“corrected” or expanded order? Is the
information updated in the system
appropriately and in a timely manner?
Are there any circumstances where incorrect billing can occur? Unless you have an
extremely tight order review process in
place this billing procedure can present
potential compliance concerns.
• • Physicians•utilizing•hospital•data•for•
billing. At first glance this might seem
like a logical approach to ensure that the
facility and physician charges match for
billing; however, most times this is not
the case. If the facility has dedicated radiology coders then there is a greater probability that the selected codes are
supported by the radiologists’ dictation.
If there are no coders, and thus no review
of the dictated report, then the codes are
selected independent of the radiologist’s
report and there is potential for error.
Additionally, while the diagnosis codes
are historically assigned correctly by
facility staff, how can you ensure that the
appropriate diagnosis code for that particular radiological study is the one
selected for claim submission?
There are other examples of billing
practices that may create incorrect billing practices and potential compliance
concerns. It is important to remember
that there is not one answer to the question of how to ensure consistency
between the technical and professional
components for billing. Every healthcare
system is set up differently and processes
and software that are utilized play a
major role. Facilities and radiologists
should consider themselves part of one
big happy family. Sometimes families
disagree, sometimes they fight, but at the
end of the day they are still family.
Melody W. Mulaik is president and co-founder of
Coding Strategies, Inc. She is a nationally recognized
speaker and has delivered numerous presentations at
AHRA annual meetings and conferences. Melody is a
member of AHRA, has published extensively, and may
be contacted at firstname.lastname@example.org.