Questions and Answers - 2004 Annual Compliance Training

Below are responses to questions that were asked at our billing compliance training sessions that we thought would be helpful to everyone. If you have any additional questions please feel free to contact Anna Evans, Peter Cadwell or Angela Blunk.

Q #1: For a Medicaid patient, if a physician assistant is billing 'incident to', must the supervising physician be immediately accessible by telephone?

A #1: The physician does not need to be in the clinic, but must be accessible by telephone or radio contact and within a reasonable travel distance. If the physician were in an operating room, he/she would not be immediately accessible.

Q #2: Does the ordering physician have to be noted in the medical chart that the physician is different than the supervising physician?

A #2: The ordering physician and the supervising physician need to be documented separately in the medical record.

Q #3: Can the compliance audits use 1995 guidelines if the documentation does not support a certain level using the 1997 guidelines?

A #3: SIU only uses 1997 guidelines for compliance audits.

Q #4: If a medical student dictates a note can the teaching physician use a statement similar to the statement used for residents, such as the teaching physician has reviewed the dictation and is in agreement?

A #4: No. Documentation (dictation) from the medical student cannot be used to level the service. However, the medical student can be used as a scribe. Please see the policy that explains using a medical student as a scribe.

Q #5: Can a sticker or stamp with the teaching physician statement be used?

A #5: Yes, if the language is appropriate and meets the guidelines. The stamp must be reviewed by the Office of Compliance prior to use by any physician or clinic. Also, the physician must still sign and date the note.

Q #6: If a patient is stable and is only seen by the resident and a note documented, does the supervising physician have to see the patient if no bill is going to be generated?

A #6: It would be recommended from a liability perspective that the physician sees the patient.

Q #7: How does the "bell curve" trigger compliance audits? If you fall out of the bell curve, does that mean you are committing fraud?

A #7: Bell curve data is used to identify coding "outliers" when compared to national averages. While falling outside the bell curve can trigger a compliance audit, documentation to support the level of service billed will determine if there are compliance issues.

Q #8: On the inpatient chart operation report is the resident allowed to document the teaching physician was present for key components?

A #8: Yes, but the teaching physician still needs to sign and date the report and the teaching physician must determine what are the key components of the surgery.