Because urine drug testing (UDT) codes don’t bring in massive reimbursement on a per-claim basis, many practices think the OIG isn’t paying much attention to these services — but that misconception can get you into trouble. In fact, the OIG frequently comes after practices that incorrectly report drug testing services, not only asking for refunds, but also levying fines and penalties as well. That’s why it’s a must to stay compliant when you report these services.
Check out three compliance tips that will help you report urine drug testing accurately every time so you can avoid OIG scrutiny and potential chargebacks.
1. Create a Payer Cheat Sheet
As most coders and billers are aware, every payer has different requirements when it comes to reporting urine drug testing, so it can be challenging to stay on top of all the unique rules. That’s why it can help to create a cheat sheet that lists every payer and its medical necessity and documentation requirements.
While Medicare and Medicaid are likely your highest risk areas, that doesn’t mean private payers won’t come after you for incorrectly reporting urine drug testing. It’s an often-audited target, mainly due to the frequency of testing, and therefore other payers may begin to take Medicare and Medicaid’s lead, pointing a spotlight at these services in the future.
After you create your cheat sheet, your work isn’t yet complete. You must stay on top of the guidelines and monitor for any changes that payers make to their requirements. Adjust your document accordingly to account for new codes, frequency guidelines, medical necessity requirements or other issues so you’re always on top of the latest news.
2. Audit to Check for Medical Necessity
Once you have your cheat sheet ready, you can start reviewing whether you’ve met medical necessity for the payers that you bill. You may be surprised to find that your documentation isn’t robust enough to demonstrate medical necessity for the testing.
For instance, Medicare allows you to report presumptive urine drug testing one to three times a month for patients with more than 90 consecutive days of abstinence. If you review your recent drug tests to find that you’ve been billing UDT four times a month for these patients, then be ready to pay back whatever reimbursement you received for the fourth monthly UDT test.
3. Train and Educate Staff
To ensure that your self-audits are operating effectively, your staff must be well trained on all aspects of urine drug test coding and billing. If they don’t know what they should be auditing for, then the audit itself isn’t worth much. Create a robust UDT compliance program, train your staff about it, answer questions, and provide training updates whenever the regulations change.
This may mean developing a training deck that includes specific, real-world UDT examples that they need to code, submit and audit on a mock basis to ensure they’re operating proficiently. Any shortcomings you find during the audit or the training can be incorporated into future compliance plans to catch issues before they happen going forward.
There’s so much more to know about urine drug testing, and that’s why Dreama Sloan-Kelly, MD, CCS, CPC is here to help. Check out her 60-minute training event, In-Office Urine Drug Testing: Avoid OIG Violations to gain the strategies you need to avoid attracting OIG scrutiny. Register today!
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