By Susan Gatehouse, RHIT, CCS, CPC, AHIMA-Approved ICD-10-CM/PCS Trainer
Recently, the Centers for Medicare & Medicaid Services (CMS) provided a temporary respite on audit activities due to the COVID-19 crisis. This was undoubtedly a welcomed break, as providers were dealing with unplanned layoffs and the furlough of employees, while at the same time, they were required to suspend nonessential procedures. Understandably, however, this respite could not go on forever, and the resumption of audit activity has been expected. ─ Now is the time to prepare, assess provider requirements, and ensure proper compliance is in place.
CMS has officially resumed the Comprehensive Error Rate Testing (CERT) Hospital Payment Monitoring Program – even though the federally declared public health emergency (PHE) was renewed in late October. As noted on the CMS website for providers, "due to the cyclical nature of the CERT program, improper payment measurement, and the statutory timeline required for improper payment reporting under the Payment Integrity Information Act of 2019 (PIIA) (i.e., reporting annually), improper payment measurements cannot pause for an extended period without missing the statutorily required due dates."
Audits may increase; however, maintaining awareness and careful management of potential risk areas will help mitigate risk and future obstacles. The key to compliance in relation to audit preparation is your capacity to remain up to date on coding and documentation requirements, and your confidence in providers' abilities to substantiate clinical documentation to support service rendered. All inquiries must be addressed immediately to ensure adequate time for review, and take action on any needed steps.
As CERT programs resume, maintaining a balance of awareness, preparation, and responsiveness will help to minimize potential cash-flow interruptions.
In an article published by RACMonitor News, Axea Solutions CEO, Susan Gatehouse outlines the steps to take in preparation for an audit. You can read the article on the RAC monitor website HERE