There has been a steady trend of increased scrutiny by governmental agencies responsible for investigating complaints against physicians and for prosecuting acts of professional misconduct by physicians, including the coding and billing practices of physicians. All practitioners should be aware that billing improprieties may constitute a form of professional misconduct that such agencies may rely upon in taking action against a physician’s medical license – up to and including revocation of a physician’s license.
Typically, awareness of governmental scrutiny comes in the form of a letter to the physician advising the physician that he or she has the opportunity to be interviewed by the agency concerning allegations of potential coding or billing improprieties. Those interviews must be taken seriously. No physician should undertake such an interview without careful and comprehensive preparation, because a failure to do so may result in inaccurate or incomplete statements being made at the interview by an unprepared practitioner, with otherwise avoidable licensure sanctions the result. (Nor should a physician ever participate in an interview without counsel present.) Part of the preparation in the context of alleged coding and billing improprieties is retaining the input of a certified coder – a service offered by Garfunkel Health Advisors – to conduct an audit of the billing records in question to see whether or not there were actionable billing errors, so that the physician is in a position to advance the strongest possible defense to the allegations.
Even those physicians who have not been the unfortunate recipient of such an agency interview letter should, on a regular basis, have a certified coder conduct a review as a preventive measure. Careful attention to one’s billing and coding practices, even when such functions are handled by outside vendors, should be high on a physician’s priority list to avoid governmental involvement.
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