Medicare audit activity heating up in Iowa.
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A new team of federal auditors this month starts combing through Medicare bills in three states looking for overpayments. If the three-year pilot is deemed a success, it could mean more scrutiny for hospitals nationwide.
The healthcare industry has changed dramatically since the first Hospital Audit Guide was published. As a result, a number of changes to the Guide itself have been proposed. Some of these revisions include widening the scope of the Guide, changes in revenue reporting, and providing guidance in covering risk contracts.
Many healthcare organizations must change the way they report patient service revenue, following provisions in the American Institute of Certified Public Accountants' recently revised healthcare audit guide. The guide directs that bad debts should be reported as expenses and that charity care should be excluded from revenue and accounts receivable. As a result, hospital executives must ensure that criteria for differentiating charity care from bad debts are in place, understood, and properly carried out.
It's not your ordinary audit. If the Internal Revenue Service decides to give your healthcare organization a Coordinated Examination Program audit, be prepared for a long haul-two to three years. And it's hard to anticipate if you'll be targeted. Catherine Jacobson, left, at Rush University Medical Center, says the IRS "told us there was no reason why they chose us, except we were on their list because of our size".
Two recent publications of the Centers for Medicare and Medicaid Services (CMS) seem to belie the view that providers can expect to see an easing of their regulatory burden under the Bush Administration. Program memorandum (PM) A-01-141, issued in December 2001, sets forth the agency's expectations with respect to audits of Medicare cost reports. PM A-01-141 instructs Medicare intermediaries "as a general rule" not to reopen a cost report or settle an appeal if the request for reopening or appeal is based on submission documentation that was not made available at the time of the audit. A proposed rule issued by CMS on January 25, 2002, would require a Medicare provider to identify and return an overpayment to its Medicare intermediary within 60 days after the provider identifies the overpayment. The proposed rule defines "overpayment" but leaves many issues open to interpretation.
A survey was conducted by authors Bitter and Cassidy to assess hospital providers' and auditors' perceptions of the reporting requirements of the new Audits of Providers of Health Care Services guide published by the American Institute of Certified Public Accountants. Responses indicated that there is still much dissent in the healthcare community as to what is useful information and what the effects of the new guide will be on hospital providers, auditors, and users.
An audit of the UB-92 should address the following questions: Are all current procedural terminology codes assigned by health information management transferred to the bill? Are all services and medications being correctly captured? Are services being "double charged" by departments that do not understand the complexity of the billing process? Are all CPT codes in the chargemaster appearing on the claims?
Long-awaited revisions to the American Institute of Certified Public Accountants' (AICPA's) auditing and accounting guide bring major changes to the ways some healthcare organizations account for charity care and bad debts, report cash flows and patient service revenue, handle risk contracting, and perform other functions. Providers not before covered by AICPA guidance and those facing accounting changes should work with their auditors to develop policies consistent with the new guidelines.
The tax-exempt status of not-for-profit healthcare organizations is being questioned and sometimes challenged on Federal, state, and local fronts. While the Internal Revenue Service (IRS) has created a special program for randomly auditing not-for-profit organizations, Congress is expected to consider legislation that would mandate the amount of charity care and community benefits a tax-exempt hospital must provide in relation to its tax-exemption value. Familiarity with IRS and Congressional activity, as well as with cases in which a hospital's tax-exempt status has been challenged in court, may provide guidelines for hospitals to assess their vulnerability.
Hospitals seeking Medicare payment are required to submit Medicare Cost Reports to their respective fiscal intermediaries, who in turn are required to desk review and sometimes audit the reports. The reviewed or audited report is considered more reliable than the originally submitted report and provides the basis for final Medicare payment. This study quantifies the impact of the review process, finding that, for the most part, the effect is quite small, usually less than 1 percent. Passthrough costs, however, were the exception to this rule. Capital and education passthrough costs, on a per discharge basis, were reduced about 6 percent.
A consulting auditing firm that reviews hospital charges incurred by members of a union covering several Midwestern states argued in court that a patient should not be required to pay the full amount of charges for services provided by a hospital in a multihospital system. The basis of the firm's argument was that the charges set by the hospital system were unreasonable because charges made by all hospitals are unreasonable. Mistakes made by the hospital during the court action caused it to lose the suit. However, the system won a second, similar suit through better preparation and documentation. This article examines both court cases and suggests methods other hospitals can use to prevail in such cases.
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Explore the source record for details and available documents.
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