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October 23, 2014 - Updated 01.12.16

Progressive Corrective Action (PCA) Review: Emergency Room Visits

The J15 Part B Medical Review department performed Progressive Corrective Action (PCA) reviews on emergency room visits throughout the year. The findings of PCA reviews occurring over 2015 are as follows:

  • Reduction in level of service for not meeting the 3 key component levels required by the code
  • Documentation failed to support the medical necessity of the service/level of service
  • No documentation to support a face-to-face encounter
  • Cloning/inappropriate templating
  • Inappropriate use of CPT modifier 25
  • Wrong/incorrect PTAN; the billing provider was not the performing provider of record
  • Signature guidelines were not followed
  • Missing signatures
  • Guidelines regarding split/shared visits were not met
  • Requirements concerning the use of a scribe were not met
  • Teaching guidelines were not met
  • Illegible documentation
  • An emergency room and an initial hospital visit were both billed on the same day by the same provider, and
  • Records were not received; records were not provided for the review.

For more information on Medicare guidelines, including documentation required to process a claim, please refer to:

Emergency Department Fact sheet:

CMS 1995/1997 Documentation Guidelines for E/M Codes

CMS Internet Only Manual

Social Security Act

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