Preparing for the Future: Preparing for the Future: Audit Risk Areas, Audit Risk Areas, Successful Appeal Successful Appeal

Strategies and Strategies and ComplianceComplianceAndrew B. Wachler, Esq.Andrew B. Wachler, Esq.

Wachler & Associates, P.C.Wachler & Associates, P.C.210 E. Third St., Ste. 204210 E. Third St., Ste. 204

Royal Oak, MI 48067Royal Oak, MI 48067

(248) 544-0888(248) 544-0888

awachler@wachler.comawachler@wachler.com

www.wachler.comwww.wachler.com

www.racattorneys.comwww.racattorneys.com

MGMA 2013 Annual ConferenceMGMA 2013 Annual Conference

October 6-9, 2013October 6-9, 2013

San Diego, CaliforniaSan Diego, California

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Learning ObjectivesLearning Objectives

Understand key audit risk areas for physician group practices.

Integrate successful strategies into Medicare appeals to defend against claim denials.

Identify specific compliance measures to implement before a Medicare audit.

Current Audit LandscapeCurrent Audit Landscape CMS contractors in the current audit CMS contractors in the current audit

landscapelandscape

Medicare Administrative Contractors (MACs) Medicare Administrative Contractors (MACs)

Zone Program Integrity Contractors (ZPICs) Zone Program Integrity Contractors (ZPICs)

Medicaid Integrity Contractors (MICs) Medicaid Integrity Contractors (MICs)

Recovery Audit Contractors (RACs)Recovery Audit Contractors (RACs) Medicare RACs & Medicaid RACsMedicare RACs & Medicaid RACs

Office of Inspector General (OIG) auditsOffice of Inspector General (OIG) audits

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Medicare Administrative Medicare Administrative Contractors (MACs)Contractors (MACs)

Statistically Projected AuditStatistically Projected Audit Statistical sampling is used to calculate and project (i.e., Statistical sampling is used to calculate and project (i.e.,

extrapolate) the amount of overpayment(s) made on claims. extrapolate) the amount of overpayment(s) made on claims. Claims are reviewed from a statistical random sample, the results Claims are reviewed from a statistical random sample, the results

of which are then extrapolated to the universe of claims during a of which are then extrapolated to the universe of claims during a given time period to determine the overpayment amount. given time period to determine the overpayment amount.

Focus/Target ReviewFocus/Target Review Contractors conduct targeted reviews, focusing on specific Contractors conduct targeted reviews, focusing on specific

program vulnerabilities inherent in the PPS, as well as program vulnerabilities inherent in the PPS, as well as provider/service specific problems. The reviews should be provider/service specific problems. The reviews should be conducted based on data analysis and prioritization of conducted based on data analysis and prioritization of vulnerabilities.vulnerabilities.

Additional Document Requests (ADRs)Additional Document Requests (ADRs) When a claim is selected for medical review, an ADR is generated When a claim is selected for medical review, an ADR is generated

requesting medical documentation be submitted to ensure requesting medical documentation be submitted to ensure payment is appropriate. Documentation must be submitted in a payment is appropriate. Documentation must be submitted in a timely manner for review and payment determination.timely manner for review and payment determination.

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Zone Program Integrity Zone Program Integrity Contractors (ZPICs)Contractors (ZPICs)

Focus on detection & prevention of Medicare Focus on detection & prevention of Medicare fraudfraud Different from the Medical Review program, which Different from the Medical Review program, which

is primarily concerned with preventing and is primarily concerned with preventing and identifying errorsidentifying errors

ZPICs request medical records and conduct medical ZPICs request medical records and conduct medical review to evaluate the identified potential fraudreview to evaluate the identified potential fraud

ZPICs may also refer to the OIG and the ZPICs may also refer to the OIG and the Department of Justice (DOJ) for further Department of Justice (DOJ) for further investigationinvestigation

Prepayment reviewsPrepayment reviews

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Two Recent ZPIC Post-Payment Two Recent ZPIC Post-Payment Review Results LettersReview Results Letters

““The ZPIC has determined that it is likely you have been The ZPIC has determined that it is likely you have been overpaid for the services provided from the end of the overpaid for the services provided from the end of the audit period through the current date based on the audit period through the current date based on the documentation submitted for the medical review. documentation submitted for the medical review. Section 1833(e) of the Social Security Act places the Section 1833(e) of the Social Security Act places the burden on the provider to furnish information necessary burden on the provider to furnish information necessary to determine the amount due to the provider.” to determine the amount due to the provider.”

““The ZPIC is requesting that the provider conduct an The ZPIC is requesting that the provider conduct an internal audit of its claims to determine the accuracy of internal audit of its claims to determine the accuracy of the claims billed. If research determines the the claims billed. If research determines the claim/payment is incorrect, please process claim claim/payment is incorrect, please process claim adjustments and arrange repayment with the claims adjustments and arrange repayment with the claims processing contractor. Please provide the ZPIC with the processing contractor. Please provide the ZPIC with the results of this audit within 90 days.”results of this audit within 90 days.”

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Medicaid Integrity Medicaid Integrity Contractors (MICs)Contractors (MICs)

Creation of Medicaid Integrity Program (MIP) mandated by Creation of Medicaid Integrity Program (MIP) mandated by Deficit Reduction Act of 2005Deficit Reduction Act of 2005 MICs hired to perform review, audit, and education functionsMICs hired to perform review, audit, and education functions

5 year look-back period5 year look-back period 3 types of MIC contractors3 types of MIC contractors

Review MICsReview MICs Audit MICsAudit MICs

30 days to provide records30 days to provide records All audit finding must be supported by adequate All audit finding must be supported by adequate

documentationdocumentation Auditors are Auditors are not not paid on a contingency fee basis and are paid on a contingency fee basis and are

not not responsible for collecting overpayments from responsible for collecting overpayments from providersproviders

Education MICsEducation MICs

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MICs ContinuedMICs Continued MIC Fraud ReferralsMIC Fraud Referrals

If an Audit MIC identifies potential If an Audit MIC identifies potential Medicare or Medicaid fraud, it must Medicare or Medicaid fraud, it must simultaneously and immediately make a simultaneously and immediately make a fraud referral to the Medicaid Integrity fraud referral to the Medicaid Integrity Group (MIG) or the Office of Inspector Group (MIG) or the Office of Inspector General for the Department of Health General for the Department of Health and Human Services (OIG). and Human Services (OIG). Medicaid Program Integrity Manual, 100-15, Ch. 10, § 10020.

The OIG has The OIG has 60 days 60 days to determine to determine whether to accept the referral. whether to accept the referral.

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Looking Forward: Looking Forward: UPICs In, MACs & ZPICs UPICs In, MACs & ZPICs

OutOut Unified Program Integrity Contractor Unified Program Integrity Contractor

(UPIC)(UPIC) CMS will be combining integrity CMS will be combining integrity

responsibilities of ZPICs and MACs into responsibilities of ZPICs and MACs into one integrity contractor one integrity contractor UPIC UPIC

MICs will be phased outMICs will be phased out Focus on both Medicare & Medicaid Focus on both Medicare & Medicaid

integrity issuesintegrity issues CMS will be consolidating Medicare and CMS will be consolidating Medicare and

Medicaid data into Medicaid data into oneone unified database unified database

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Medicare Recovery Audit Medicare Recovery Audit Contractors (RACs)Contractors (RACs)

Private companies contract with MedicarePrivate companies contract with Medicare Identify Medicare overpayments and Identify Medicare overpayments and

underpaymentsunderpayments Paid on a contingency fee basisPaid on a contingency fee basis Started as a demonstration project in 2005Started as a demonstration project in 2005 Section 302 of the Tax Relief and Health Care Section 302 of the Tax Relief and Health Care

Act of 2006 made the RAC program permanentAct of 2006 made the RAC program permanent Required nationwide expansion by 2010 Required nationwide expansion by 2010

The Patient Protection and Affordable Care Act The Patient Protection and Affordable Care Act (PPACA) expanded the RAC program to Medicaid (PPACA) expanded the RAC program to Medicaid and Medicare Parts C and Dand Medicare Parts C and D

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Who are the RACs?Who are the RACs?• Region ARegion A: Performant Recovery: Performant Recovery

• Working in CT, DE, D.C., MA, MD, MA, NH, NJ, NY, PA, RI Working in CT, DE, D.C., MA, MD, MA, NH, NJ, NY, PA, RI and VTand VT

• www.dcsrac.comwww.dcsrac.com• Region BRegion B: CGI Technologies and Solutions, Inc. : CGI Technologies and Solutions, Inc.

• Working in KY, IL, IN, MI, MN, OH and WIWorking in KY, IL, IN, MI, MN, OH and WI• http://racb.cgi.comhttp://racb.cgi.com

• Region CRegion C: Connolly Consulting, Inc.: Connolly Consulting, Inc. • Working in AL, AR, CO, FL, GA, LA, MS, NC, NM, OK, SC, Working in AL, AR, CO, FL, GA, LA, MS, NC, NM, OK, SC,

TN, TX, VA and WVTN, TX, VA and WV• www.connollyhealthcare.com/RACwww.connollyhealthcare.com/RAC

• Region DRegion D: HealthDataInsights, Inc.: HealthDataInsights, Inc.• Working in AK, AZ, CA, IA, KS, MO, MT, ND, NE, NV, OR, Working in AK, AZ, CA, IA, KS, MO, MT, ND, NE, NV, OR,

SD, UT, WA, WY, Guam, American Samoa and Northern SD, UT, WA, WY, Guam, American Samoa and Northern MarianasMarianas

• http://racinfo.healthdatainsights.com/home.aspxhttp://racinfo.healthdatainsights.com/home.aspx

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Medicaid RACsMedicaid RACs States were required to have implemented their Medicaid States were required to have implemented their Medicaid

RAC programs by January 1, 2012 RAC programs by January 1, 2012 Medical necessity reviews for Medicaid RACMedical necessity reviews for Medicaid RAC

● CMS will not issue oversight provisions CMS will not issue oversight provisions ● Reviews will be performed within scope of state laws and Reviews will be performed within scope of state laws and

regulations regulations ● The Medicaid RAC Final Rule does not require Medicaid The Medicaid RAC Final Rule does not require Medicaid

RACs to receive prior approval for medical necessity RACs to receive prior approval for medical necessity reviews.reviews.

The The ACA requires states to contract with RACs, but states are free to contract with any RAC. As a result, there is significant variability between the states - there are 50 different sets of rules, and 50 different appeal processes. 

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Physician Audit Risk Physician Audit Risk AreasAreas

Home Services – Care Plan Oversight Home Services – Care Plan Oversight (CPO)(CPO) Focus on overutilization of Care Plan Oversight Focus on overutilization of Care Plan Oversight

(CPO) Services.(CPO) Services. Provided by a physician to a patient under home Provided by a physician to a patient under home

health agency or hospice care that requires health agency or hospice care that requires complex and multidisciplinary modalities complex and multidisciplinary modalities involving regular physician development and/or involving regular physician development and/or revision of care plans, review of subsequent revision of care plans, review of subsequent reports of status, etc. reports of status, etc.

Time spent for services is 30 minutes or more per Time spent for services is 30 minutes or more per calendar month. calendar month.

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Physician Audit Risk Physician Audit Risk Areas Areas

Emergency Department ServicesEmergency Department Services Denial reasons for services include:Denial reasons for services include:

Failure to submit physician’s notes Failure to submit physician’s notes documenting component work with medical documenting component work with medical record;record;

Key work was not performed by the Key work was not performed by the physician or mid-level provider; physician or mid-level provider;

Documentation failed to meet the key Documentation failed to meet the key components for the level of coding.components for the level of coding.

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Physician Audit Risk Physician Audit Risk AreasAreas

““Incident-to” ServicesIncident-to” Services The OIG assesses whether “incident-to” The OIG assesses whether “incident-to”

services have a higher error rateservices have a higher error rate The OIG stated that “incident-to” The OIG stated that “incident-to”

services represent a program services represent a program vulnerability that does not appear in vulnerability that does not appear in claims data claims data Can be identified only by reviewing the Can be identified only by reviewing the

medical recordmedical record

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Physician Audit Risk Physician Audit Risk AreasAreas

Physician Responsibilities for DME and Physician Responsibilities for DME and Home Health ProvidersHome Health Providers Physicians are required to retain Physicians are required to retain

documentation for diagnostic or documentation for diagnostic or specialist services they order for specialist services they order for patients (i.e. DME, home health, and patients (i.e. DME, home health, and IDTF) IDTF)

CMS or a Medicare contractor may CMS or a Medicare contractor may request this documentation from a request this documentation from a provider. (42 C.F.R. 424.516)provider. (42 C.F.R. 424.516)

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Physician Audit IssuesPhysician Audit Issues

E/M coding E/M coding Documentation does not support the level Documentation does not support the level

of service billed (i.e., upcoding or of service billed (i.e., upcoding or downcoding of services)downcoding of services)

Required components are not documented Required components are not documented in the medical recordin the medical record

The historical component is incomplete or The historical component is incomplete or absentabsent

The medical decision-making documented The medical decision-making documented is inappropriate or incompleteis inappropriate or incomplete

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Examples of New RAC Approved Examples of New RAC Approved Issues Affecting PhysiciansIssues Affecting Physicians

Incorrect Billed Drug and Biological HCPCS CodeIncorrect Billed Drug and Biological HCPCS Code Providers are required to report appropriate HCPCS codes Providers are required to report appropriate HCPCS codes

for the drugs and biologicals administered and billed. for the drugs and biologicals administered and billed. Medical documentation will be reviewed to determine that Medical documentation will be reviewed to determine that the appropriate HCPCS code was billed. (At this time, the appropriate HCPCS code was billed. (At this time, Medical Necessity will be excluded from this review.)Medical Necessity will be excluded from this review.)

Blepharoplasty – eyelid liftsBlepharoplasty – eyelid lifts When done for cosmetic purposes, it does not meet the criteria of When done for cosmetic purposes, it does not meet the criteria of

the functional visual impairment parameters and is considered not the functional visual impairment parameters and is considered not reasonable and medically necessary. reasonable and medically necessary.

Intensity-Modulated Radiation Therapy (IMRT) Intensity-Modulated Radiation Therapy (IMRT) IMRT is only covered for certain diagnosis and when certain IMRT is only covered for certain diagnosis and when certain

conditions are metconditions are met Excessive Units of Multiple Drug Class ScreeningsExcessive Units of Multiple Drug Class Screenings

Effective January 1, 2011, HCPCS codes G0431 and G0434 for Effective January 1, 2011, HCPCS codes G0431 and G0434 for multiple drug class screenings may only be reported once per multiple drug class screenings may only be reported once per patient encounter regardless of the number of drug classes tested.patient encounter regardless of the number of drug classes tested.

Other Physician Audit Other Physician Audit IssuesIssues

Extended ServicesExtended Services Oncology/HematologyOncology/Hematology Computed Tomography AngiographiesComputed Tomography Angiographies Medical necessityMedical necessity

Surgical proceduresSurgical procedures Cataract surgeriesCataract surgeries Cardiology proceduresCardiology procedures Cardiac testingCardiac testing

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Other Physician Audit Other Physician Audit IssuesIssues

Pain managementPain management EPO: medical necessity and LCD EPO: medical necessity and LCD

requirementsrequirements Urological procedures: medical Urological procedures: medical

necessity and LCD requirementsnecessity and LCD requirements Home physician servicesHome physician services

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Medicare & MedicaidMedicare & MedicaidOverpaymentsOverpayments

PPACA Section 6402(d)PPACA Section 6402(d) Requires providers and suppliers receiving funds under Requires providers and suppliers receiving funds under

the Medicare program to report and return overpayments the Medicare program to report and return overpayments by the later of (1) the date which is 60 days after the date by the later of (1) the date which is 60 days after the date on which the overpayment was identified or (2) the date on which the overpayment was identified or (2) the date any corresponding cost report is due, if applicable.any corresponding cost report is due, if applicable.

• Expands liability to include knowing failure to repayExpands liability to include knowing failure to repay “…“…knowingly and improperly avoids or decreases an knowingly and improperly avoids or decreases an

obligationobligation to pay or transmit money or property to the to pay or transmit money or property to the Government.” Government.”

Proposed Rule (77 Fed. Reg. 9179)Proposed Rule (77 Fed. Reg. 9179) 10-year look-back period10-year look-back period

Recent case law: Recent case law: United States and State of Wisconsin ex United States and State of Wisconsin ex rel. Keltner v. Lakeshore Medical Clinic, LTDrel. Keltner v. Lakeshore Medical Clinic, LTD

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Successful Audit Appeals Successful Audit Appeals Strategies:Strategies:OverviewOverview

Rebuttal and Discussion PeriodRebuttal and Discussion Period RedeterminationRedetermination

Appeal deadline: 120 days (30 days to avoid recoupment) Appeal deadline: 120 days (30 days to avoid recoupment)

Reconsideration Reconsideration Appeal deadline: 180 days (60 days to avoid recoupment)Appeal deadline: 180 days (60 days to avoid recoupment)

Administrative Law Judge HearingAdministrative Law Judge Hearing Appeal deadline: 60 daysAppeal deadline: 60 days CMS will recoup the alleged overpayment during this and CMS will recoup the alleged overpayment during this and

following stages of appealfollowing stages of appeal

Medicare Appeals Council (MAC)Medicare Appeals Council (MAC) Appeal deadline: 60 daysAppeal deadline: 60 days

Federal District CourtFederal District Court Appeal deadline: 60 days Appeal deadline: 60 days

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Successful Appeals Strategies: Successful Appeals Strategies: Arguing the MeritsArguing the Merits

Merit-based arguments:Merit-based arguments: Medical necessity of the services providedMedical necessity of the services provided Appropriateness of the codes billed Appropriateness of the codes billed Frequency of servicesFrequency of services

To effectively argue the merits of a claim:To effectively argue the merits of a claim: Draft a position paper laying out the proper coverage Draft a position paper laying out the proper coverage

criteriacriteria Summarize submitted medical records and documentationSummarize submitted medical records and documentation If relying on medical records in an ALJ hearing: If relying on medical records in an ALJ hearing:

Organize using tabs, exhibit labels and color coding Organize using tabs, exhibit labels and color coding Use graphs and medical summaries to assist in the Use graphs and medical summaries to assist in the

presentation of evidencepresentation of evidence

Use of past Medicare Appeals Council cases Use of past Medicare Appeals Council cases http://www.hhs.gov/dab/divisions/medicareoperations/mac

decisions/mac_decisions.html http://www.hhs.gov/dab/macdecision/

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Successful Appeals Strategies:Successful Appeals Strategies:Use of ExpertsUse of Experts

Experts such as physicians, registered nurses, Experts such as physicians, registered nurses, coding experts, and inpatient rehabilitation coding experts, and inpatient rehabilitation specialists may be helpful in appealing a contractor specialists may be helpful in appealing a contractor determination determination

Experts canExperts can: : Assess strength of a case early on and help develop a Assess strength of a case early on and help develop a

strategic planstrategic plan Assist with the interpretation and organization of medical Assist with the interpretation and organization of medical

records records Provide testimony regarding appropriateness and/or Provide testimony regarding appropriateness and/or

necessity of servicesnecessity of services Affidavit at redetermination and reconsideration levelsAffidavit at redetermination and reconsideration levels Live testimony at ALJ hearing Live testimony at ALJ hearing

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Successful Appeals Strategies:Successful Appeals Strategies:Audit Defenses Audit Defenses

• Provider Without FaultProvider Without Fault• Waiver of Liability Waiver of Liability • Treating Physician’s RuleTreating Physician’s Rule• Challenges to StatisticsChallenges to Statistics

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Successful Appeals Strategies:Successful Appeals Strategies:Provider Without Fault Provider Without Fault

Section 1870 of the Social Security Act Section 1870 of the Social Security Act •Once an overpayment is identified, Once an overpayment is identified, payment will be made to a provider if payment will be made to a provider if the provider was without “fault” with the provider was without “fault” with regard to billing for and accepting regard to billing for and accepting payment for disputed services payment for disputed services

Definition of faultDefinition of fault 3 Year Rule3 Year Rule

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Successful Appeals Strategies: Successful Appeals Strategies: Waiver of Liability Waiver of Liability

Section 1879(a) of the Social Security Act Section 1879(a) of the Social Security Act •Under waiver of liability, even if a service Under waiver of liability, even if a service is determined not to be reasonable and is determined not to be reasonable and necessary, payment may be rendered if necessary, payment may be rendered if the provider or supplier did not know, and the provider or supplier did not know, and could not reasonably have been expected could not reasonably have been expected to know, that payment would not be made.to know, that payment would not be made.

Successful Appeals Strategies:Successful Appeals Strategies:Challenges to StatisticsChallenges to Statistics

Section 935 of the MMASection 935 of the MMALimitations on Use of ExtrapolationLimitations on Use of Extrapolation –– A Medicare contractor A Medicare contractor may not use extrapolation to determine overpayment amounts to may not use extrapolation to determine overpayment amounts to be recovered by recoupment, offset, or otherwise, unless the be recovered by recoupment, offset, or otherwise, unless the Secretary determines that Secretary determines that

There is a sustained or high level of payment error; or There is a sustained or high level of payment error; or Documented educational intervention has failed to correct Documented educational intervention has failed to correct

the payment error.the payment error.Cannot challenge the substance of the finding of Cannot challenge the substance of the finding of ““sustained or sustained or high rate of error,high rate of error,”” but can challenge whether a finding was made but can challenge whether a finding was madeGuidelines for conducting statistical extrapolations are set forth Guidelines for conducting statistical extrapolations are set forth in the Medicare Program Integrity Manual (CMS Pub. 100-08), in the Medicare Program Integrity Manual (CMS Pub. 100-08), Chapter 3, §§ 3.10.1 - 3.10.11.2Chapter 3, §§ 3.10.1 - 3.10.11.2

SeeSee also also MAC caseMAC case Transyd Enterprises, LLC d/b/a Transpro Medical Transyd Enterprises, LLC d/b/a Transpro Medical

Transport Transport

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ComplianceCompliance

Comparative Billing ReportsComparative Billing Reports Snapshot of utilization data for an individual provider Snapshot of utilization data for an individual provider Provider’s billing pattern for a given code or group of codes Provider’s billing pattern for a given code or group of codes

is compared to the state average and the national averageis compared to the state average and the national average Mailed to the top 5,000 billersMailed to the top 5,000 billers CBR examples:CBR examples:

E/M servicesE/M services Podiatry: nail debridementPodiatry: nail debridement Cardiology services Cardiology services

Compliance Policy on InvestigationsCompliance Policy on Investigations Compliance and Organizational Tips to Compliance and Organizational Tips to

Prepare for an AuditPrepare for an Audit

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Compliance Policy on Compliance Policy on InvestigationsInvestigations

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Have policies on cooperation and coordination with Have policies on cooperation and coordination with government investigations in placegovernment investigations in place

If an employee receives any inquiry, subpoena, or other legal If an employee receives any inquiry, subpoena, or other legal document relating to the employer’s business:document relating to the employer’s business: Notify the Compliance Officer immediately, who will contact legal counselNotify the Compliance Officer immediately, who will contact legal counsel Never provide false or inaccurate information to a government investigatorNever provide false or inaccurate information to a government investigator

On-Site Government InquiriesOn-Site Government Inquiries Obtain “initial contact” informationObtain “initial contact” information Contact Compliance OfficerContact Compliance Officer Draft memorandum regarding information obtained from the investigator Draft memorandum regarding information obtained from the investigator

and provide to Compliance Officerand provide to Compliance Officer

Search WarrantsSearch Warrants Notify the Compliance Officer immediately, who will contact legal counselNotify the Compliance Officer immediately, who will contact legal counsel

Employees speaking with government investigators:Employees speaking with government investigators: Cannot be prohibited from speaking with government investigators, but Cannot be prohibited from speaking with government investigators, but

may politely declinemay politely decline May request legal counsel to be present during an interview May request legal counsel to be present during an interview

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Compliance and Compliance and Organizational Tips to Organizational Tips to Prepare for an AuditPrepare for an Audit

Be aware of your RAC’s new approved issuesBe aware of your RAC’s new approved issues Designate a person to check the approved issues Designate a person to check the approved issues

lists on a regular basis lists on a regular basis Be aware of improper payments that have Be aware of improper payments that have

been identified in OIG and CERT reportsbeen identified in OIG and CERT reports OIG: OIG: www.oig.hhs.gov/oas/cms.asp CERT: CERT: www.cms.hhs.gov/cert/

Implement proactive compliance measures Implement proactive compliance measures Self audits (prospective vs. retrospective)Self audits (prospective vs. retrospective) DocumentationDocumentation

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Compliance and Compliance and Organizational Tips to Organizational Tips to Prepare for an AuditPrepare for an Audit

Availability of internal experts Availability of internal experts Determine who could act as an expert for the different Determine who could act as an expert for the different

specialties in your institutionspecialties in your institution Appeals – how will you handle?Appeals – how will you handle? Learn from past appeal experiences Learn from past appeal experiences

Keep track of denied claims Keep track of denied claims Look for patterns of denialsLook for patterns of denials Develop necessary corrective action Develop necessary corrective action

Call to ActionCall to Action

Outline the audit landscape and Outline the audit landscape and stay stay current current with new developmentswith new developments

Identify Identify key audit risk areas key audit risk areas that that affect your practice affect your practice

Develop Develop proactive compliance proactive compliance measures measures that will help your that will help your practice prepare for and mitigate practice prepare for and mitigate the impact of an auditthe impact of an audit

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QUESTIONS?QUESTIONS?Andrew B. Wachler, Esq.Andrew B. Wachler, Esq.

Wachler & Associates, P.C.Wachler & Associates, P.C.

210 E. Third St. Ste. 204210 E. Third St. Ste. 204

Royal Oak, Michigan 48067Royal Oak, Michigan 48067

(248) 544-0888(248) 544-0888

awachler@wachler.comawachler@wachler.com

www.wachler.comwww.wachler.com

www.racattorneys.comwww.racattorneys.com