Hospital Associations Respond to Letter About Upcoding From HHS, DOJ

In response to a letter from HHS and the Department of Justice about the misuse of electronic health records, the Association of Academic Health Centers and American Hospital Association separately defended hospitals and requested further guidance from CMS.

Steven A. Wartman, MD, PhD, CEO and president of AAHC, which represents more than 100 academic medical centers, said several of its member institutions and their chief compliance officers have expressed concern about the availability of clear, useful guidance related to the coding of evaluation and management services.

"Those concerns have only been exacerbated by the increased uptake of electronic health records and the rapid changes in the delivery system necessary to accommodate more sophisticated technology," he wrote.

Dr. Wartman also said members are concerned about "the system of incentives for and oversight of Medicare [Recovery Auditors]." He concluded its letter by requesting a meeting with appropriate officials to discuss the issues more in-depth.

The AHA also responded to the agencies' letter, noting that CMS has not yet established national coding guidelines for evaluation and management services.

In the letter, AHA President and CEO Rich Umdenstock wrote, "No one questions the need for auditors to identify billing mistakes, but the flood of new auditing programs, such as RACs, MACs and others, is drowning hospitals with a deluge of redundant audits, unmanageable medical record requests and inappropriate payment denials."

Mr. Umdenstock concluded by noting that well-intended payment accuracy programs "need to be streamlined," and investments should be made in provider education to prevent coding mistakes before they occur.

More Articles on Providers and Upcoding:

HHS, DOJ to Hospitals: Don't "Game the System" With EHRs
Center for Public Integrity: Billing Abuse, Upcoding on the Rise
AHA Fights Back Against Allegations EHRs May Cause Upcoding Fraud


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