A March 11 article in Part B News, “Warning: Minor Errors Can Mean Big Takebacks for AWV Claims,” discussed how compliance shortcomings can cause problems for claims to Medicare for annual wellness visits (AWVs). Rivkin Radler’s Mary Aperance was quoted in the article.

“Routine internal audits should be conducted to hone in on documentation or billing errors that can range from isolated instances to more systemic ones that could ultimately lead to a voluntary self-disclosure,” Mary said. “Oftentimes, the payer denies payment for services provided because a provider’s underlying documentation satisfies all but one requirement to bill a particular CPT code,” she observed, adding that she’s seen psychological service claims “denied for not including an ‘individualized treatment plan’ as a standalone document despite the fact that the underlying clinical notes contained all of the elements of an individualized treatment plan.”

Bad claims might result from billing errors by a management services organization (MSO) that manages the practice. Mary said that the relationship between the practice and the MSO “should be governed by an agreement that details the specific services to be provided by the MSO, and often includes a provision indemnifying the medical practice against liabilities incurred as a result of the MSO’s intentional or negligent acts. This can help to protect the medical practice if, as an example, an overpayment is owed to a payer as a result of negligent billing errors by the MSO.”