July 1, 2011
A Message from the Medical Director
A topic that continues to receive national attention is the Comprehensive Error Rate Testing Program (CERT). With that in mind I'd like to take this opportunity to share a brief synopsis of this program and your role as Medicare providers.
What is CERT?
CERT was developed several years ago by the Centers for Medicare and Medicaid Services (CMS) to randomly sample claims on a monthly basis clinically review those claims to determine if they were billed and processed correctly. The outcomes of these reviews serve as the basis for the national estimate of wasteful spending in Medicare and receive significant attention in politics and the media.
Why is CERT important?
The intent of the CERT program is to protect the Medicare Trust Fund by identifying error rates at both the national and regional levels and used by CMS to evaluate the performance of Medicare contractors. This information is also used to identify trends such as; which specialties or codes are driving the errors, and how to allocate future program integrity resources.
How is CERT data used?
As Medicare Contractors we analyze CERT findings to help focus our Medical Review efforts, expand our educational programs, and develop Local Coverage Determinations (LCDs).
How does CERT impact you, the provider?
Once your claim has been selected in the random sample you will receive a request for documentation from the CERT contractor outlining details of the program, the needed documentation, and directions for submitting your documentation. To ensure your letter is a valid CERT request, the first page contains the CMS logo, a barcode, and has been signed by Jill Nicolaisen the CMS CERT Government Task Leader. Be assured that forwarding specifically requested records to the designated CERT contractor does NOT violate privacy provisions under the HIPAA law. The Centers for Medicare & Medicaid Services (CMS) has contracted with the CERT Documentation Contractor and the CERT Review Contractor to conduct the activities of the CERT program. As a Medicare contractor and in accordance with Section 1816 and 1842 of the Social Security Act, the CERT contractors are authorized to request claims and medical records from providers and suppliers of Medicare services. Physicians, providers and suppliers do not need to obtain additional beneficiary authorization to forward medical records to the designated CERT contractor.
It is important that you comply with CERT request timely, not responding or submitting insufficient documentation will result in a CERT denial and recoupment of funds.
What can you do to lower the CERT error rate?
In the clinical setting errors refer to a mistake, in the CERT setting an error mostly applies to a failure to properly document or submit information that is necessary to validate the medical necessity of a test or procedure. Often an error is identified NOT because a test or treatment was NOT necessary but rather the error is due to inappropriate documenting or coding. For that reason I encourage you to remember a few simple tips:
- make sure that all required information is documented in the medical record,
- make sure all documents are signed by the person providing the service,
- make sure you submit ALL documentation related to the CERT claim
- make sure you submit all lab results and orders for those labs
- make sure you always submit signed orders
- make sure you submit documentation from third parties such as hospital notes when appropriate
Where can you find more information about CERT?
- CGS Administrators, LLC website: www.cgsmedicare.com
- CGS CERT Coordinator: Julene Lienard 615-782-4591
- CMS Website: https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/CERT/index.html