MDaudit announced today the release of Service Provider Workflow. This latest enhancement to its industry-leading billing compliance and revenue integrity platform supports billing when rendering providers differ from service providers, reducing audit risks related to the billing of split/shared services.
Under changes to its Evaluation and Management (E/M) guidelines, the Centers for Medicare and Medicaid Services (CMS) require split/shared services — which are performed jointly between a physician and a non-physician practitioner (NPP) in the same group and in a facility setting — to be reported by the clinician who performs the substantive portion of the patient visit.
To qualify for billing under the physician’s national provider identifier (NPI), which nets a higher rate than those billed by NPPs, the physician must have performed more than half of the provided care, as determined either by time spent or through evaluation of key components including history, examination, or medical decision-making.
“Service providers perform and document services under the supervision of the rendering provider. However, under current CMS E/M guidelines, the claim is no longer billed by the rendering provider unless they have performed a substantive portion of the care, which introduces a new layer of complexity and compliance risk into the billing process,” said Catherine Proctor senior product manager, MDaudit. “MDaudit’s new Service Provider Workflow functionality reduces that risk by allowing customers to include the service providers who aren’t on the claim as part of an organized audit.”
Users can efficiently organize line service providers into provider groups and audit both professional- and hospital-based service providers. It also features the flexibility to perform audits at the rendering, attending, or service provider level, organize audits at the line service provider level, and exclude cases from rendering/attending provider-organized audits when different line service providers are involved.
“The benefits of this new process are numerous, including a better root cause analysis for errors and the ability to provide feedback directly to documenting service providers while more easily targeting residents, ‘incident to’ providers, locum tenens, and split/shared services,” said Proctor. “Service Provider Workflow features were popular asks from the MDaudit community, and we are excited to deliver them to our clients to help further reduce their audit risk.”
External payer audits quadrupled in volume in 2023, making timely responses more challenging than ever for resource-strapped healthcare organizations. Though patient volumes and surgeries have begun to recover from COVID-19 declines – with a 23% and 27% increase over 2022 – inflation, staffing shortages, reimbursement, and regulatory issues continue to jeopardize the financial health of healthcare organizations nationwide.
These were among the key findings of the 2023 MDaudit Annual Benchmark Report released today by MDaudit, an award-winning provider of technologies and analytic tools that enable the nation’s premier healthcare organizations to minimize billing risk and maximize revenues.
Ritesh Ramesh
“Increased complexity and reduced resources mean healthcare organizations are operating in an environment that demands flawless optimization for billing compliance, coding, and revenue integrity capabilities,” said Ritesh Ramesh, CEO of MDaudit. “Our analysis reveals the urgency for healthcare systems to stay ahead of the curve by harnessing digital initiatives and advanced technologies, including AI, machine learning, and analytics, to proactively manage compliance and revenue risks.”
Beyond technology, healthcare leaders must break down the silos between teams to create cross-functional/departmental synergies and manage change to stay operationally efficient. This will be imperative for growth and profitability going into 2024.
Shrinking Teams Face Growing Compliance and Revenue Integrity Challenges
Amidst nationwide healthcare staffing shortages, technology, automation, and analytics have emerged as critical catalysts for health system executives to drive change. Leaders are leveraging these tools to boost productivity, generate revenue, and control costs while compensating for reduced staffing levels. Managing denials and ensuring timely payments are important, but even more crucial is understanding and addressing the root causes of issues that start upstream with billing and coding practices in provider operations.
Across the MDaudit customer base, there was an increase in technology-driven productivity. Large auditing teams were able to accomplish 10% more in audit activities compared to 2022 with more or less the same resources.
Medicare Advantage plans were under constant scrutiny from the Federal government for compliance and overpayments. The data shows that these plans rejected 25% more in reimbursement dollars to providers this year versus 2022.
Telehealth remains a substantial contributor to compliance and revenue challenges. According to MDaudit data, telehealth volumes were flat relative to last year and an average of 30% of audits failed for services administered in a patient’s home or office. Proficiently coding and documenting these crucial charges is imperative for ensuring the ongoing success of patient care and favorable outcomes.
In 2023, external payer audits surged fourfold compared to 2022, often involving large audit documentation requests (ADRs). Mounting requests with tight deadlines and appeal timelines posed a significant risk of revenue loss and potential clawbacks, creating challenges for hospitals because of staffing issues.
Mitigating Denials to Protect Revenues
MDaudit’s findings emphasized the crucial role revenue integrity and billing compliance play in supporting the accurate and ethical capture and optimization of revenue for services rendered to patients. These teams are crucial for preserving financial stability, sustainability, and compliance, all while upholding the commitment to delivering high-quality patient care. Billing and coding are not about revenue alone; these cross-functional workflows directly influence patient experience and relationships, as well as a healthcare organization’s ability to grow.
Health systems are burdened by denials and increasing demand, underscoring the vital need for operational efficiency in billing, coding, and clinical documentation to enhance profitability.
The MDaudit analysis also found that:
Commercial payers are taking longer to respond to claims in 2023 vs 2022. Initial response times were 29 days (about six business weeks) for an outpatient claim and 35 days (about seven business weeks) for an inpatient claim.
MDaudit data for 2023 shows the value of commercial payers’ initial denials for professional claims has increased by 30% and by 5% for inpatient claims, as compared to 2022.
Medicare Part A and Part B rejected 16% of the claims initially submitted for outpatient services – the most profitable for healthcare organizations.
More than 60% of professional billing claim denials in 2023 were driven by documentation requests and eligibility concerns from payers.
“As we move into 2024, proactive actions and precision on billing compliance and revenue integrity outcomes are no longer optional. The healthcare landscape is evolving, affecting every facet of this industry,” said Ramesh. “New payer strategies and the integration of AI have intensified denials, payment delays, and claim scrutiny. How organizations and providers adapt and respond to these challenges will shape their long-term success.”
About the Report
The MDaudit Annual Benchmark Report equips compliance, HIM/coding, revenue integrity, and finance executives with industry insights, emerging trends, and data-driven information to help them take informed action and enhance outcomes for their organizations. The analysis in this report includes a comprehensive examination of data collected from a network of over 650,000 providers and more than 2,200 facilities that provide data to MDaudit for auditing, charge analysis, and denial assessment. This report encompasses insights from more than $5 billion in audited professional and hospital claims and denials by both commercial and government payers exceeding $150 billion.
Healthcare organizations are in a precarious financial position. With operating margins still hovering near zero, revenues are at heightened risk because of a surge in third-party audits following the expiration of the public health emergency as well as increased scrutiny by federal and commercial payers alike to identify – and recover – billions in improper payments and penalties.
This sharp uptick in audit activity has many healthcare organizations – even those that have already adopted revenue cycle management (RCM) technologies to streamline workflows – struggling to comply with both the volume of incoming documentation requests (ADRs) and the timeframes within which they must reply.
The appearance of artificial intelligence (AI), specifically conversational AI, is promising to change that, making it possible to convert the highly unstructured data populating the audit process into information that can be both analyzed and automated.
The Audit Environment
Ferreting out fraud and abuse remains high on the federal government’s priority list. In fiscal year 2022, the U.S. Department of Justice (DOJ) collected more than $1.7 billion in improper payments, while the Office of the Inspector General (OIG) reported identifying more than $200 million in expected audit recoveries and over $277 million in questioned costs in its 2023 Semi-Annual Report to Congress.
Meanwhile, the Centers for Medicare & Medicaid Services (CMS) is expected to claw back $4.7 billion from Medicare Advantage plans over the next decade thanks to recent adjustments to its risk adjustment data validation (RADV) program. Add to all that the influx of demand letters in the wake of the expiration of the federal PHE – along with many of the waivers that kept external audits in check – as well as claim changes and heightened regulatory and billing practice scrutiny by federal contractors and commercial payers.
All this comes at a time when hospital margins remain “well below historical norms,” per Kaufman Hall, and revenue cycle leaders are facing severe labor shortages, with more than 41% reporting that up between 51% and 75% of RCM and billing department roles are currently vacant.
Healthcare organizations undoubtedly felt a sense of relief as 2022 faded in the distance, taking with it a devastating financial performance that resulted in negative profit margins for more than half of U.S. hospitals – the worst year hospitals have faced since the start of the pandemic, according to Kaufman Hall. Not only were operating margins down for most of 2022, but hospitals also struggled with higher labor costs in a more competitive market plagued by chronic clinical and administrative skill shortages.
Physician practices fared no better, with 90% saying that soaring expenses outpaced revenues last year, according to a survey by the Medical Group Management Association. Staffing and labor costs were cited most often as the source of rising costs. Other common culprits were lower reimbursement rates, significant increases in lab supply and drug costs, higher utility costs, lower patient volumes, and rising malpractice premiums.
The new year does not mean healthcare organizations are out of the financial woods, however. A plethora of new challenges to the bottom line have emerged, led by a sharp uptick in third-party audits. Supported by a $2.5 billion budget for the Healthcare Fraud and Abuse Control and Medicaid Integrity programs, federal payers are stepping up both pre-payment and retrospective claim audits – and private payers are following suit. This not only increases the risk of penalties and claw backs, but it also slows claims processing and, subsequently, reimbursements and puts greater pressure on providers to submit clean claims the first time.
Five Revenue Integrity Trends
To avoid a repeat of 2022’s dismal financial performance, revenue integrity leaders surveyed by MDaudit are placing a priority on revenue opportunities (34%), compliance pressures (29%), revenue risks (29%), and staffing issues (9%). For 37% of respondents, all these issues are top of mind for 2023.
These concerns align closely with the focus on growth, revenue, and profitability that dominate most organizational planning – and is evident in the following key revenue integrity trends identified in the 2022 Annual Benchmark Report.
MDaudit, an award-winning provider of technologies and analytics tools that enable premier healthcare organizations to retain revenue and reduce risk, announced today the retirement of its long-time president and CEO, Peter J. Butler, effective Mar. 31, 2023. Stepping into the CEO role will be the company’s current COO, Ritesh Ramesh.
Butler will continue serving on MDaudit’s Board of Directors and as an investor, advising on future investments and growth opportunities for the company. He has been with MDaudit for 30 years, including the past 16 as president and CEO.
“My tenure with MDaudit has been truly rewarding, but it is time for me to pursue my personal goals,” said Butler, who was the visionary behind the company’s successful transition from consulting to technology. “By remaining on the board, I get the best of both worlds; the opportunity to start the next chapter of my life while supporting Ritesh as he guides MDaudit’s continued innovation and strengthens its position at the leading edge of the revenue integrity marketplace.”
Ramesh joined MDaudit in 2019 as CTO and played an integral role in the company’s conversion to a technology organization focused on supporting the healthcare industry’s evolution toward revenue integrity. In 2021, he was recognized by the Globee Awards as Chief Technology Officer of the Year in the 16th Annual IT World Awards and in 2020 won Silver in the 8th Annual CEO World Awards, Executive Achievement of the Year for Information Technology Services category. Ramesh was promoted to COO in 2021 and has been leading MDaudit’s customer and technology teams to fuel the company’s growth and ongoing innovation in the revenue integrity marketplace.
“It is an honor to take the helm of MDaudit and build upon our mission of delivering innovation through technology-enabled healthcare revenue integrity,” said Ramesh. “We have a great culture, growing customer base, and a market leading platform. We will continue to focus on delivering the next-generation tools and innovative partnerships that transform revenue cycle management and compliance strategies and empower our customers to strengthen revenues and stay ahead of regulatory risks.”
Maintaining an organization’s revenue integrity should be a constant activity for compliance and auditing staff. Consider that, despite falling claim volumes in Q3 compared to the first two quarters of 2022, the average denial per claim increased by as much as 9.6%, according to the 2022 MDaudit Annual Benchmark Report. Lag days between claims submission and initial payer response also rose by as many as 6.5 days during the same period.
For health information management (HIM) professionals, this should serve as a wakeup call to make every claim count. Increasingly, organizations are using “risk intelligent” auditing to continuously monitor risk, detect anomalies, and automate workflows to bring efficiencies to formerly manual processes. Organizations that make resolving accuracy issues in billing and coding operations a priority can help retain between 15% and 25% of overall revenue. Revenue retention is going to be as critical as revenue growth for healthcare organizations going into 2023.
Read on to learn how to help your organization keep more of its hard-earned dollars.
Leveraging data to drive outcomes
Not long ago, coding, billing, claims, and auditing processes often operated independently of one another and employed tedious and manual workflows. These processes slowed claims submissions, payments, and auditing functions that help organizations maintain compliance and monitor revenues.
These time-consuming and cumbersome processes became more problematic during the pandemic, when the very foundations of the traditional care experience were upended by a novel disease and the rise of the virtual patient visit. While providers continue to recover from these shocks to their organizations, federal payers have ramped up their efforts to ensure the accuracy of claims.
During FY 2023, the federal Health Care Fraud and Abuse Control (HCFAC) Program and the Medicaid Integrity Program will receive nearly $2.5 billion, an increase of $80 million from the previous year. Inclusive of medical review, Medicare program integrity activities had a return on investment (ROI) of $8 for each $1 spent. With such an attractive return, don’t be surprised that the breadth and depth of these activities continues to increase.
Organizations can support risk-based compliance and revenue integrity by utilizing risk intelligent auditing to mine their billing and remit data to identify billing compliance and revenue risks. The same tools can unearth key metrics focused on current risk areas to monitor provider billing patterns and even benchmark them against peers. Risk intelligent auditing helps prioritize efforts to develop corrective action plans, educate stakeholders, mitigate the need for audits, and prevent future revenue losses.
With 82% of 2022 claims denials associated with Medicare, and third-party audit volume rapidly climbing, hospitals and health systems are under intense pressure to protect and grow revenues.
These were among the key findings of the 2022 MDaudit Annual Benchmark Report released today by MDaudit, the healthcare technology company that harnesses the power of analytics and its proven track record to allow the nation’s premier healthcare organizations to retain revenue and reduce risk.
Peter Butler
“Our analysis suggests that the post-pandemic era has given rise to a new phenomenon for healthcare. Medical spending is more discretionary for consumers impacted by inflation, driving dramatic reductions in revenues generated by physician office and hospital visits for the third quarter of 2022,” said Peter Butler, president and CEO, MDaudit. “Exacerbating this situation is the need to successfully defend against more third-party audits amidst chronic personnel and resource shortages.”
Driving Smarter Audits
Payers are investing in predictive modeling and artificial intelligence (AI) tools to scrutinize claims more closely before adjudication to reduce improper payments. The 2023 Department of Health and Human Services budget requests $2.5 billion in total investments for the Healthcare Fraud and Abuse Control and Medicaid Integrity Programs, $900 million of which is allocated for discretionary spending to advance technologies to scrutinize payment accuracy — up $26 million from 2022.
This should be a concern for healthcare organizations – and the push compliance leaders need to find more efficient ways to retain at-risk revenues. Per the MDaudit analysis:
Billing compliance leaders mustleverage data and analytics as catalysts to proactively detect risks and perform audits for corrective action. Data-driven, risk-based audits (up 28% in 2022) can complement the annual compliance plan to ensure effective audit scope coverage.
By deploying prospective (up 31% in 2022) and retrospective auditing methods, compliance teams can drive cross-functional initiatives that mitigate compliance and revenue risks.
Defending Revenues
A key element of a successful revenue defense is to help compliance teams become more efficient in managing external payer audit requests to retain at-risk revenues. The role of billing compliance needs to be increasingly data-driven and cross-functional, as well as serving as a business partner to other teams including coding, revenue integrity, finance, pharmacy, and clinical, to meet changing and more complex risks. The MDaudit analysis also found that:
The Centers for Medicare and Medicaid Services (CMS) has made no secret of its intentions to crack down on fraud, abuse, and waste, throwing more budget dollars into audits, heightening program integrity oversight of Marketplace plans, and exploring new methods of using advanced technology to conduct more rapid and thorough documentation reviews.
Historically, as CMS goes, so do commercial payers, putting healthcare organizations in the crosshairs of an unprecedented level of third-party external audits. To emerge relatively unscathed, organizations need to put in place proven processes that guide immediate and effective actions in the wake of adverse findings.
With limited time to correct the internal processes or billing practices that contributed to the problems, many organizations are turning to corrective action plans (CAPs) to streamline and accelerate their response to unfavorable outcomes. Those that do also realize the added benefit of having their chances of future billing compliance risks significantly reduced while their ability to achieve revenue integrity is enhanced.
The Audit Environment
The signs of an aggressive audit environment are everywhere. The Department of Health and Human Services (HHS), in its 2022 budget, allocated a staggering $2.6 billion to halting fraud, abuse, and waste in its Medicare and Medicaid programs – up from $180 million in 2021. A primary target is Medicare medical review of fee-for-service claims – which CMS has likely increased due to a robust rate of return to the Trust Funds (estimated to be more than $9-to-$1, based on a three-year rolling average).
The Office of the Inspector General (OIG) has also ramped up its scrutiny of how well provider organizations complied with requirements tied to the use of nearly $180 billion in Provider Relief Funds and with recently enacted mandates such as the No Surprises Act. One survey found that almost 25% of hospitals respond to as many as 2,000 external audit-related monthly requests from multiple sources. While results of many of those audits are confidential, Medicare Fee-for-Service data show a 6.26% improper payment rate in their 2021 report.
When audits by commercial payers identify problems such as overpayments, they may require the provider organization to generate and implement an actionable CAP for the relationship to continue. And while a CAP is not required when a RAC audit uncovers issues with billing practices, the offending provider organization should act swiftly to not only remedy the immediate problem – generally by refunding the overpayments – but also to identify and address any underlying practices or processes that may put the organization at risk for future issues and liability.
Audit pressure isn’t just external. Many healthcare organizations are also ramping up internal scrutiny – and they’re not always happy with the findings. When looking specifically at internal audits, the Healthcare Auditing and Revenue Integrity: 2021 Benchmarking and Trends Report from MDaudit found that more than 30% of the time, audit outcomes are unsatisfactory and have not met acceptable thresholds.
MDaudit announced today the release of Service Provider Workflow. This latest enhancement to its industry-leading billing compliance and revenue integrity platform supports billing when rendering providers differ from service providers, reducing audit risks related to the billing of split/shared services.
