Corporate

March 10, 2014

Radiation Oncology: Top Billing and Documentation Errors

Based on CERT Data from the sampling period July 2012 through June 2013, as of January 15, 2014, "Radiation Therapy" listed among the top 10 errors by type of service, with a projected error rate of 42.7%. The following are actual CERT errors:


Case #1: Orders, Plans, and Signatures

Submitted CPT codes:

  • 77414- Radiation treatment delivery, 3 or more separate areas
  • 77417- Radiology port film(s)

Records submitted:

  • Patient treatment history
  • Notes for dates of service other than the date requested
  • Patient radiation prescription
  • Treatment planning note (contains initials only, where records indicate "approved by")
  • Copy of x-ray film (missing patient's name)

Missing from the submitted documentation:

  • Radiation order
  • Initial treatment plan
  • A physician signature or attestation statement from the physician who approved the radiation dose and treatment planning note

Outcome: the service was denied for insufficient documentation to support the billed service.


Case #2: Treatment Notes and Medical Necessity for IMRT

Submitted CPT code:

  • CPT code 77418, intensity modulated radiation therapy (IMRT)

Records submitted:

  • Radiation prescription and plan
  • Physician consultation notes
  • Treatment and radiation oncology notes

Missing from the submitted documentation:

  • The administration of billed Intensity Modulated Radiation Treatment (IMRT) Delivery
  • The billed Radiation Physics Consults for dates of service; and supports the special need for performing IMRT rather than performing conventional or 3-dimensional treatment planning and delivery.

Outcome: additional records were requested but not received. The service was denied for insufficient documentation to support the billed service.


Case #3: Treatment Records, Treatment Plans, and Orders

Submitted CPT code:

  • 77427- Radiation treatment management x5.

Records submitted:

  • Chemotherapy records
  • Lab results
  • Physician's note (not signed)
  • Discharge instructions
  • Upon second request, the following additional records were submitted: follow-up note; end of treatment summary; consultation note; multiple CT results; pathology results; colonoscopy results; and EGD results.

Missing from the submitted documentation:

  • Radiation treatment records to support the radiation treatment management, 5 treatments
  • Physician orders for the radiation treatment management, 5 treatments
  • Radiation treatment plan

Outcome: the service was denied for insufficient documentation to support the billed service.


Tips for improving the accuracy of submitted records:

  • The two most common errors noted among claims for radiation oncology services are failing to send supporting documentation and submitting records without a valid signature. These errors are preventable, and we encourage you to take immediate steps to ensure that your medical records staff understands what records to submit. We recommend you review all medical records, before submitting claims, to ensure they contain valid signatures which meet Medicare's signature requirements.
  • Although the CERT process involves a very small sample of records, we have found that any errors identified in the sample are often present in other records.
  • We strongly encourage you to review these errors and incorporate awareness of these errors into your practice's quality procedures.

Reference:

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