1. Tenet indicted for physician recruitment scheme
2. Documentation improvement tips for the medical staff
3. Pay-per-view article: When to create facility-specific coding guidelines
4. HMO pays $96,923 in duplicate payments
5. Tip: Appearances do matter

When Tenet Health System paid $10,000,000 to fund more than 100 physician relocation programs, it made a costly mistake. In addition to paying the physicians to relocate, Tenet also paid the physicians to refer patients to Alvarado Hospital, according to the U.S. Attorney for the Southern District of California.

The 17-count indictment also alleges that Tenet paid the "host" medical practices with whom the recruited doctors were placed, in exchange for patient referrals. Among the arrangements described in the indictment were relocation agreements with four physicians who joined the practice of Dr. Paul Ver Hoeve, located in the Alvarado service area. The defendants arranged for Ver Hoeve personally to receive at least $600,000 of the relocation agreement money.

The indictment charges defendants with one count of conspiring to violate the federal anti-kickback statute, and with 16 counts of offering and paying illegal remuneration. Each count carries a maximum penalty of five years imprisonment and a $25,000 fine.

We can trace inadequate documentation to the root of the health care industry's current problems-from substandard patient care to financial loss. Documentation is the key to appropriate charge capture, and an incomplete or inaccurate record forces health information managers (HIM) to query physicians. That slows the billing process and, in turn, cash flow. Documentation errors lead to fraud and abuse, non-compliance with standards set by the Joint Commission on the Accreditation of Healthcare Organizations, and inaccuracies in statistical databases. Make sure your physicians are documenting appropriately. To help, purchase the handbook, "Documentation Improvement Handbook for the Medical Staff." Here's an example of the information this handbook offers physicians:

Question: What are the best practices for documenting informed consent to minimize liability for myself as the treating physician and the facility?

Answer: Informed consent for a procedure or anesthesia is a process between the physician and the patient, according to current legal opinions. As a physician, you have the responsibility to document that you discussed your assessment and recommendations with the patient, including the risks and benefits of the recommended course of treatment and other treatment options. If this discussion occurs between the physician and the patient (and sometimes the patient's family), it stands to reason that the physician should document this activity in the medical record. All too often, physicians count on a hospital's or other facility's staff to obtain a patient's signature on an informed consent form as adequate documentation.

Physicians should sit down with the patient, including his or her family if appropriate, and dedicate adequate time and attention to the process of obtaining informed consent.

Immediately after this activity, the physician should document in the medical record that the activity occurred and include a brief summary of the content discussed.

It seems to take forever to get official coding guidance and once it's published, the guidance doesn't always answer all related coding questions on the subject; this invariably causes more frustration for coders. The long waits for guidance are due to the collaboration between the four cooperative parties involved in creating coding guidelines: the American Hospital Association (AHA), the American Health Information Management Association, the National Center for Health Statistics, and the Centers for Medicare & Medicaid Services, says Nelly Leon-Chisen, RHIA, director of coding and classification for the AHA.

One Medicare contractor may need to review what it does to prevent duplicate payments, according to a recent audit report from the Office of Inspector General (OIG). Welborn Health Plan, a cost-based health maintenance organization, paid two providers $96,923 in duplicate Medicare payments.

The OIG found that Welborn also claimed $700 in unallowable costs on its fiscal year 2000 cost report. That means that $35,280,509 of the costs that Welborn claimed on its Medicare cost reports were reasonable, allowable, and allocable.

The OIG recommends that Welborn do the following: