8 June 2021
When money goes to a healthcare provider from the federal or state government, there is always the risk of audit and/or investigation. There are a variety of auditing agencies known by their acronyms — OIG, DOJ, CMS, MAC, RAC, ZPIC — and each has its own interpretation of what the regulations require. The post-COVID-19 world is no exception.
In fact, regulatory activity has already been initiated on several fronts. The speed with which money has been disbursed, along with the flurry of new codes, waivers and regulations, has opened the door to fraudsters — but also created possibilities for innocent mistakes and unintentional misreporting.
Inpatient claims account for much of the money potentially at risk. To capture COVID-19-related data in a consistent fashion, several new ICD-10-CM diagnosis codes have been created, most of which are off cycle from the customary October 1st effective date. New guidelines have been introduced as well, and many will affect payment in some way. For example, the assignment of certain COVID-related diagnosis codes can result in a 20% upward adjustment on top of the typical inpatient MS-DRG payment from Medicare.
Therefore, the ever-watchful eye of the regulators will be closely examining submissions. Compliance officers, coding and billing leaders, revenue integrity leaders and counsel should take note of the following important COVID-related ICD-10 coding rules, including the time period that each coding change went into effect.
For further information, please contact:
Matt.schwartz@fticonsulting.com
