If you use a third-party provider to handle your billing, don't assume
they're using updated codes. It's not a defense to an audit that you
outsource your billing to a third party. Consultants can help you navi-
gate and implement coding changes if you don't have the time or
resources to do so internally.
Even technical violations of CMS coding and documentation
requirements are difficult to defend. The best defense against audits is
to, quite simply, get your house in order. Do it now. Make the time and
make it a priority. Perform a self-audit, communicate the necessary
changes in process and practice to your staff, and mandate compli-
ance. Break free of complacency and sleep better at night.
OSM
Mr. O'Carroll (tocarroll@hinshawlaw.com) is a partner in the Chicago
office of Hinshaw & Culbertson. He has defended providers in claims brought
by CMS, as well as claims of overpayment by private insurance carriers.
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