When it comes to compliance violations, service lines with the most repeat visits are also the most likely to be “repeat offenders.” Yet most of these specialties – including behavioral healthcare and rehab – have little political clout within the hospital and are seldom on the CFO’s radar.
That’s about to change.
Most CFOs realize that the historically cordial relationship with OIG auditors is being replaced by the profit-driven RAC audit system. But they don’t realize that the service lines most vulnerable to costly RAC penalties are the ones that fly under the radar. Behavioral healthcare isn’t glamorous, and rehab isn’t something you tout in hospital TV ads. Yet these service lines involve multiple visits that invite scrutiny.
Many surgeries and hospital procedures are one-shot affairs. For example, a RAC audit team isn’t likely to delve too deeply into a cardiac stent procedure. There’s one date of service, with the documentation to support it. Case closed.
But in the case of rehab treatment, the therapist’s plan of care must be signed-off on by the referring physician – or none of the services rendered down the line are deemed medically necessary. If the rehab therapist is affiliated with the hospital, that means that perhaps a dozen patient visits are in violation – resulting in lost revenue, back payments and penalties.
In other words, the hospital CFO is in the leaky boat from Jaws while the RAC auditor circles around slowly.
Once RAC auditors spot a pattern of noncompliance, they can even extrapolate additional fines. They can say, “We’ve looked at 100 charts and found a 15 percent error rate. But you saw 10,000 patients in the last three years, so we’re going to multiply the back payments and penalties by 100. And by the way, that payment is due normal">now.”
This scenario is true not just for rehab, but for other multiple-visit service lines like pediatrics and psychiatry. One minor compliance violation can get magnified for months.
That’s why there are legislative measures like the U.S. Senate bill that aims to extend meaningful use incentives to behavioral healthcare. Without comprehensive IT interoperability across all service lines, one omission in a paper chart can turn into a cascade of back payments and penalties.
The cost of integrating repeat-visit EMR data into a hospital’s primary longitudinal EHR system is miniscule compared to the cost of hefty RAC fines. Especially when those penalties date back four years and are multiplied across 20 hospitals in a chain.
You can be sure that RAC auditors are circling the boat, on the prowl for repeat offenders. And that vessel needs EMR interoperability now more than ever.
Gerry Stone is founder and CEO of The Rehab Documentation Company in Nashville, Tenn.