Tip: Resolving past coding errors
Healthcare Auditing Weekly, March 27, 2007
Did you attend a conference recently and find out that someone in your organization has been coding something incorrectly for the past 10 years? The situation is not unheard of and you do have an obligation to correct the past errors in some cases. How you need to act depends on the nature of the error discovered. Sometimes coding errors don't result in payment errors at all, according to Timothy Blanchard, JD, McDermott Will & Emery, Los Angeles.
Consider if it was purely a mistake or if it rose to the level of recklessness. If it's just a mistake, it shouldn't trigger False Claims Act exposure, but may nevertheless trigger a need to refund reimbursement for some period.
With respect to mistakes, the period Blanchard recommends to clients is the four-year reopening period, during which Medicare can reopen claims if there's no evidence of fraud or other fault on the part of the provider.
Editor's Note: This tip first ran in HCPro's Compliance Monitor.
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