Fixed Assets Property Control

USA Health has a policy, Property Control Procedures Manual [PolicyStat ID 6069645] related to the proper control and safeguarding of fixed assets/equipment. The manual details the departmental responsibility as well as the responsibility of the Purchasing, Environmental Services and Receiving departments and that of the Property Control Accountant. Major Movable Equipment is defined as any item of equipment, apparatus, machinery, furniture, or fixture not normally attached to or made part of a building’s structure that costs $5,000.00 or more and has a useful life of two (2) years or more. Inventory tagging procedures and the requirements for periodic inventories are documented within the policy as well.

May was Internal Audit Awareness Month

Thank you to those who participated in our first official celebration of Internal Audit Awareness Month! We enjoyed sharing a bit about ourselves and our profession, and especially meeting new folks, or those we have only met virtually!

Internal Audit Annual Risk Assessment

It’s that time of the year again…Risk Assessment time! In general, a risk assessment is the process used to identify risk factors that have the potential to negatively impact achievement of an organization’s goals or objectives. The Office of Internal Audit completes the risk assessment via a combination of interviews with senior leaders and managers, a Qualtrics survey, evaluation of industry specific risks, among other factors. The risk assessment is a key component in the creation of the annual audit plan. View our 2022 Risk Assessment Flyer to learn more about the process!

Billing Codes for Procedures and Diagnoses

Accurate selection of Procedure Codes and the associated Diagnosis Codes is crucial in supporting medical necessity for the services rendered.

Ensuring your providers and or coding departments are staying up to date with current ICD-10-CM coding guidelines is the first step to filing compliant claims. The following are some examples of incorrect coding:

• Upcoding – assigning an inaccurate code to increase reimbursement
• Unbundling – coding procedures separately that were performed at the same time
• Coding for services not rendered
• Coding for diagnoses not addressed or treated by the provider
• Unspecified diagnoses codes when a more specified code is documented

All claims for Government payors are routed through the Centers of Medicare & Medicaid Services (CMS) for payment. CMS routinely audits claims using random sampling and, depending on the type of audit, may employ “Zone Program Integrity Contractors” (ZPICS) or “Recovery Audit Contractors” (RAC) to conduct the actual audit with the providers. Areas with probable high rates of inaccuracy are targeted for potential fraud committed against the Government. It is essential for everyone to understand the False Claims Act and how an incorrect diagnosis and/or procedure code assigned to a filed claim could be viewed as fraud.

The False Claims Act (FCA)

Under the civil FCA, no specific intent to defraud is required.¹ The civil FCA defines “knowing” to include not only actual knowledge but also instances in which the person acted in deliberate ignorance or reckless disregard of the truth or falsity of the information. Filing false claims may result in fines of up to three times the programs’ loss plus $11,000 per claim filed.

The USA Health Office of Billing Compliance is tasked with the responsibility of reviewing provider claims for the accuracy of both procedure and diagnosis codes. All incorrect diagnoses and/or procedures noted are communicated to providers and/or the management of the respective coding teams. Any discrepancies identified that require refunds will have corrected claims filed, if applicable, and monies can be recouped by payors or refunded by the billing office.

USA Health Fraud & Abuse Policy [PolicyStat ID 8445396] outlines the Government’s rules, regulations and laws pertaining to the FCA. If you have any questions about assigning the appropriate procedure or diagnoses codes to a provider claim, please contact the Billing Compliance Department at 251-434-3500 or via email at cholland@health.southalabama.edu.

[1] U.S.Code Title 31, Chapter 37, Subchapter III, Sections 3729-3733