- Don’t Panic and Don’t Ignore It! An audit letter is not an automatic presumption of guilt. Some audits are completely random and conducted routinely with no suspicion cast toward your billing activities, documentation ability or treatment parameters. So do not panic in the presence of an audit letter. Don’t assume that your documentation is substandard. Don’t automatically determine they will find your records insufficient and make plans to be subversive. On the other hand, do not ignore the audit letter. Instead, plan to take action.
- Can I even be audited? You do have legal rights depending on the state in which you practice and your specific situation. For example, if you are an out of network provider, there is a possibility that the carrier cannot audit unless they suspect fraud. On the other hand a governmental entity like Medicare definitely can audit you, so move on to the next step. Perform your due diligence immediately and research this issue.
- Determine exactly what the audit letter states. Are they requesting a chart audit where they want to look at your medical records? Do they want to perform a site visit? Once you’ve determined which type of audit they’re intending to conduct on your practice, you need to formulate response to that audit or to the request that the audit’s making in a timely manner. In some types of audits, no answer is the worst possible answer you could give. So you want to respond in a timely manner to the request for the audit. Also, provide what is requested: nothing more, nothing less. The auditors do not want to review a 42 page explanation of your chart notes; they should stand for themselves. Furthermore, any additional material you provide beyond what is requested can be used against you as well. One tip: do not respond to phone or fax audit requests. Get it in writing!
- Do Not Alter Your Documentation. I get many emails and calls from chiropractors who have received an audit letter. The most common question is: “what do I need to do to prepare for this audit?” To be blunt: the time to prepare for your audit is not when an audit request letter is in your hands! Never take matters into your own hands and alter medical records to improve what appears to be incomplete or insufficient documentation. Poorly done records are still better than the best records that have been fraudulently contrived.
- Determine IF You Can Meet Audit Requests. If the time frame that the carrier is requesting is not reasonable due to some sort of extenuating circumstances, contact the auditor for an extension. If it’s going to take you more time to produce the information, ask for an extension.
- Is this something we need to appeal immediately? If your “audit” letter is actually a demand for repayment, your best option may be to start the appeals process. Do not automatically presume that the payor’s review is final or even correct. If appropriate, an appeal can save you thousands of dollars in unnecessary repayments and headaches.
- Is this something for which you will experienced assistance? You may need to obtain the assistance of a certified professional coder or a certified professional medical auditor whose expertise is in chiropractic (such as myself) to help defend you. A healthcare attorney may also be wise, especially if there are several zeros in your demand or repayment letter. Again, before you hit the panic button or get out your checkbook, it may be critical to the success of your defense or appeal to get professional help. The reality is that your license, your lifestyle and your livelihood may all depend on it!
I hope that you found this article helpful. For a more detailed discussion on audits, I suggest you check out my program “How to Prepare Your Chiropractic Practice For Recovery Audits.” For specific questions regarding your own audit situation or letter, you may contact me per the guidelines below.
Due to the large volume of requests that I receive for audit advice, opinions and requests from chiropractors to “look this over and tell me what this means,” I can no longer respond to phone inquiries on this matter. If you have need for an opinion or objective discussion on audits or demand letters, the need for attorney/ legal representation or appeals, please contact me via a separate email for this purpose at Audits[at]StrategicDC.com.