B. The following audit
guidelines will be followed by hospitals and carrier/self-insured employer.
Disputes between the carrier/self-insured employer and hospitals will be
referred to the Office of Workers Compensation for final resolution.
1. Carrier/Self-Insured Employer
Responsibilities
a. The claims to be audited
should be identified as quickly as possible after the carrier/self-insured
employer receives the claim.
b. The
carrier/self-insured employer or its audit agency should give 10 calendar days
advance notice to the hospital of its desire to perform an audit. The
carrier/self-insured employer or its audit agency should make an appointment to
do the audit at the time that is mutually agreed to by both parties. At the
time the appointment is made, the hospital shall be informed of:
i. the name(s) of patient(s) whose records
are to be audited;
ii. the
admission and discharge dates for each case;
iii. the medical record numbers and billing
numbers of the claims to be audited, as assigned by the hospital, if those
appear on the claim;
iv. the
name(s) of the auditor(s) who will conduct the audit, if available, and the
name of the audit firm if the carrier/self-insured employer is contracting for
auditing services;
v. the portion
of the bill to be audited (i.e., drugs, respiratory therapy, etc.) if the
entire bill is not to be audited.
c. Qualified individuals familiar with
hospital billing practices, medical terminology and medical record charting
must be used to perform the billing audit.
d. Auditors must be properly authorized and
identified as representatives of the carrier/self-insured employer or its audit
agency.
e.
i.Recognizing that no single standard exists
for the payment of hospital bills prior to audit, or for audit fees charged by
hospitals, the Office of Workers' Compensation recommends the following
guidelines.
(a). The carrier/self-insured
employer should pay at least 80 percent of billed charges prior to the audit.
If an audit fee is charged by the provider, it should not exceed $50 per
patient record plus copy charges as provided below.
(b). The carrier/self-insured employer will
reimburse the hospital for copies of medical records at the following rates:
Fees will not exceed $15 per record for 1-20 pages, and $0.30 per page for
records in excess of 20 pages. Microfilm copies will not exceed $0.50 per
page.
ii. Should the
carrier/self-insured employer and hospital not be able to agree to this
standard or some other standard, either party may submit the dispute to the
Office of Workers' Compensation Administration in the same manner and subject
to the same procedures as established for dispute resolution of claims for
workers' compensation benefits.
f. Auditors should itemize specific
unsupported charges and unbilled charges found on hospital bills. The final
audit findings will offset unbilled charges against unsupported charges in a
reconciliation process to be completed by the carrier/self-insured employer
after receiving the audit report which should include a listing of all unbilled
charges and unsupported billings.
g. Auditors should conduct exit interviews
with a hospital's audit coordinator and/or other appropriate hospital personnel
prior to leaving to permit the review of the preliminary audit results before
issuing a final report. If the exit interview is waived by the hospital, this
fact should be indicated in writing.
h. A written report of the final audit
results should be sent to all interested parties in a timely fashion.
2. Hospital Responsibilities
a. Hospitals must schedule an appointment to
audit a bill promptly upon the receipt of a request for such an appointment, at
a time mutually agreed upon by the hospital and the carrier/self-insured
employer or its audit agency no later than 10 days from receipt of
request.
b. Hospitals should
respond promptly to a request for an itemized bill from the
carrier/self-insured employer or its agent.
c. Hospitals should respond promptly to
requests for additional information on the period of hospitalization, including
information from the medical record and from the billing office.
d. Hospitals should designate one individual
to be responsible for coordinating all hospital audit activities, and act as a
liaison between provider personnel and the carrier/self-insured employer. This
would include informing appropriate hospital departments of pending audits and
audit results, answering carrier/self-insured employer questions, insuring that
a late charge bill is sent to the patient or carrier/self-insured employer,
issuing a refund to the appropriate party, etc. After notice of a proposed
audit has been received by the hospital, this individual should coordinate
between the medical records department and the billing office to insure that
medical records, financial records, and any other documentation needed to
substantiate charges are provided and available for the audit.
e. The hospital liaison shall acquaint the
carrier/self-insured employer representative or audit agent with its record
system and charging practices.
f.
All substances administered to the patient in any form, as well as all
treatments or medical services, must be specifically and accurately
documented.
g. The hospital's
representative will be available to the carrier/self-insured employer to
conduct an exit interview. Discrepancies will be reviewed, resolved, and agreed
upon by both parties. This will be done by written confirmation of the unbilled
and/or undocumented charges identified during the audit and signed by both
parties. In the event that same day resolution is not possible, the hospital,
in a timely manner, should resolve differences in any unsupported or unbilled
amounts resulting from the audit.
h. The hospital should issue refunds promptly
if overcharges and/or undocumented charges exceeding the balance of the
carrier/self-insured employer liability are discovered during the
audit.
i. Hospitals may not bill
for undocumented charges discovered during the bill audit process. However,
hospitals may bill for documented and previously unbilled charges discovered
during the bill audit process, for charges in excess of the audit fee charged
by the hospital.