Do You Have What It Takes to Win?
By Sally Eggleston, MBA, RT(T)

Many private practice physicians are asking themselves: Do I have what it takes to win? By winning, maybe they mean staying in private practice and not becoming an employee of a hospital. Or maybe it's reporting PQRS correctly in order to not be penalized and lose revenue. Or it could be something as simple as winning at cards with their kids or grandkids. I hope the answer to two of these questions isn't just "yes" but "you betcha!" For the purpose of this article, we'll keep it simple: Do you have what it takes to not only survive in your practice but win a CERT audit?

In "Radiation Oncology: Top Billing and Documentation Errors," CGS Medicare indicates that radiation oncologists aren't as capable of winning a CERT review as we would like to think.

Based upon data from July 2012 to June 2013, CGS indicates a projected error rate of 47 percent. Keep in mind this was not a large sampling—but still, such a high error rate is not acceptable. The article details a number of documentation component issues that we'll cover here.

Missing orders is one. It's a common area of consternation among our seasoned consultants at Revenue Cycle Inc. You've probably heard the frequently-used assertion that a patient can't get an aspirin in the hospital without the proper order being included in the medical record, but he can sure get a dose of radiation from a CT or linear accelerator. The issue here is really twofold. Radiation oncologists tend to occasionally not include orders for all procedures such as simulations, immobilization devices and dosimetry calculations. But along with them, the personnel responsible for working the CERT review, appeal, etc. are not always sufficiently educated in radiation oncology and the frequently used EHRs to submit the information. Mistakes can happen when a hospital-based physician relies on the hospital to perform billing services and be knowledgeable about ARIA and/or MOSAIQ—systems to which the hospital employee may not have access or even know. Unfortunately, this occurs in private practices, too.

Submission of medical records without a valid signature is also a very common occurrence. This is confounding for a couple of reasons. Why would a physician not want to sign his/her work and why would a person responsible for working a denial/appeal/review not check to ensure the documentation was signed before sending it? Radiation oncologists need to give some serious thought to what it would be like to sit on a witness stand trying to prove to a jury or judge that they really did perform a service but were just too busy to sign the document. It's a frightening scenario. And there's a very real risk of having to refund money, not only for a few services but for months of work if a review was expounded due to a CERT review. While attestation statements could possibly be generated depending on the procedures, the time it would take to create them is much more burdensome than just electronically signing all documentation in a CMS-approved manner in the first place. The published CMS information regarding approved electronic signatures can be found here: Program Integrity Manual (Pub. 100-08), chapter 3, section

As you know, there's a lot of potential for error. But you don't have to end up in that failing 47 percent. With some attention to detail, improved and efficient documentation processes and the resolve to be compliant, your oncology practice can win at CERT audits.

Let RC Billing help. From assessment and review to staff training, implementation and compliance, RC Billing can keep your audits—and your practice—running smoothly, navigating you through updates and paperwork so you can focus on quality care. To find out more about what RC Billing can do for you, contact us at 512-583-2000 or email us at


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