Clinical documentation: Choose your physicians wisely

A. I feel your pain and understand the challenge associated with this task.  

First, if the physician is telling you that no one else is asking for the documentation, he/she is probably not being truthful. Most providers in this current environment know the importance of obtaining documentation to support their claims, so hold that physician accountable.

Remind them of their legal obligation to comply and provide the statute indicating that. Approach them from a compliance perspective. Indicate that for your company to be in compliance with federal regulations, you need this documentation. If other companies aren't requesting it, they may not be in compliance. Hopefully, they would rather work with a company that is compliant.

Of course, I understand the fine line you're walking. We like to use the recent change to the Program Integrity Manual in our communication with physicians. It says, “Physicians/LCMPs (licensed/certified medical professionals) who fail to submit documentation upon a supplier's request may trigger increased MAC or RAC review of the physician/LCMP's evaluation and management services.” Explain to them that to avoid additional and unnecessary scrutiny on your company, as well as their practice, you really must have the documentation. It's a very effective argument. Physicians' claims are being audited much more frequently now, so this may certainly get their attention.

If all this fails, you have to make a decision whether or not you are willing to accept the liability of working with an uncooperative physician. Unless you have a properly executed advance beneficiary notice, then the liability lies with you as the supplier. We all know, in this current environment, that the risk is great. Choose wisely.

Wayne van Halem is president of The van Halem Group. Reach him at 404-343-1815 or wayne@vanhalemgroup.com