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January 12, 2016

Progressive Corrective Action (PCA) Review: Assisted Living and Nursing Facility Visits

The J15 Part B Medical Review department performed Progressive Corrective Action (PCA) reviews on assisted living and nursing facility visits throughout the year. The findings from PCA reviews occurring over 2015 are as follows:

  • Failure to meet the key component levels required for the code billed,
  • The documentation did not support the minimum components required for the lowest level code
  • The documentation did not support a face to face encounter
  • Medical necessity issues
    • Medical necessity was not supported
    • The frequency in which services were billed was medically unnecessary
    • Cloning
  • Illegible documentation
  • The guidelines for split/shared visits were not followed
  • The guidelines the use of a scribe were not followed,
  • Signature guidelines were not followed
  • No signature was found on the medical record
  • The documentation supported hospice patient visits
  • Inappropriate use of CPT modifier 25
  • Routine foot care - No documentation of a separately identifiable service above and beyond the debridement of nails Failure to provide medical records for the review

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

CMS 1995/1997 Documentation Guidelines for E/M Codes

CMS Internet Only Manual

Nursing Facility Fact sheets:

Social Security Act

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