Ambulatory Surgery Centers Facing Increased Coding Compliance Scrutiny

Scrutiny of coding compliance in ambulatory surgery centers (ASCs) from both Medicare and private payers has been on the rise in recent years, and will continue to be a factor in coding compliance audits looking forward.

The increased scrutiny takes a closer look at issues that are not necessarily new, bringing to light standing issues. “With highly complex rules and requirements seemingly changing by the day, a widespread lack of awareness about coding compliance is a continual challenge for many ASCs,” according to an article from Becker’s ASC Review. According to the article, a report from the Office of Inspector General (OIG) in 2010 that was focused on ASCs and skilled nursing facilities (SNFs) found that “Medicare contractors nationwide made at least $6.6 million in overpayments to ASCs for services subject to consolidated billing.” The same report included the conclusion that many ASCs were simply unaware of or did not fully understand the regulations with which they were supposed to comply when it comes to coding.

Whether or not ASCs are aware of their mistakes, however, the penalties are very real, including claims denials, audits, fines, and exclusion from federal payer programs, according to the article. Some tips for compliant coding practices from the article include:

  • Checking bills against operative notes to guarantee compliance
  • Unbundling codes is often a red flag that will draw payer attention to what might be an inappropriately coded circumstance
  • Do not upcode, or list procedures that are not documented; no documentation means it can’t be billed
  • Review payer guidelines when reporting unlisted codes and relevant supporting documentation

Some ASC-related issues that OIG is currently looking into include:

  • Payment methodology
  • ICD-10 implementation
  • Anesthesia service coding

“Running afoul of coding rules… is not a foregone conclusion,” the article states. “Implementing best practices and fostering a collaborative work environment can eliminate many coding compliance risks.”

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