In 2010 the Centers for Medicare and Medicaid Services (CMS) began to release Comparative Billing Reports (CBRs). A CBR compares provider to provider billing practices, both regionally and nationally, to determine if a provider is an “outlier”, or billing outside of the expected pattern. If a provider is found to be an outlier, they will receive a notification detailing the analysis and erroneous billing, while offering education on the topic. CBRs review many areas of billing, and even topics outside of billing. Some common topics include; evaluation and management, modifier utilization, and groups of specific codes, for example, radiation modality treatments for oncology providers or dialysis visits for nephrology providers. It's also important to note that CMS is not the only one reviewing billing practices in this manner. Other large commercial payers have similar programs, such as UnitedHealthcare’s Peer Comparison Reports, which functions much like the CBR.
CMS and other payers perform CBRs and similar reports with the goal of providing educational resources and outreach. This outreach ensures compliance with coding and billing standards and reduces potential fraud, waste, and abuse. CBRs can also ultimately help patients. Most patients are unaware of the many coding and billing rules that exist and therefore have a difficult time identifying when they have been overcharged. This can lead to costly out-of-pocket expenses toward co-insurance and deductibles. Educating providers can offer a real impact on reducing a patient’s financial burden.
While CMS says “receiving a CBR is not an indication of or precursor to an audit” the receipt of a CBR can still be a stressor, especially if a provider or practice does not have the right tools to internally investigate the CBR findings, or worse, does not know where to begin to address a CBR. The risk of removing focus from the patient care to address these billing practices is high. Additionally, ignoring the report altogether could place the provider and practice at risk for more CBRs in the future and even potential audits. CBRs should be promptly reviewed and addressed by taking the following steps:*
One of the best defenses for CBRs and other billing challenges is to practice proactive risk analysis, or regular and consistent monitoring to identify potential billing issues before they begin. Proactive risk analysis can easily be achieved by utilizing the data that already exists within your billing software. Reports that visually display information such as charge capture counts or evaluation and management level distribution can be particularly useful. The same reports can then be combined with CMS benchmarking data, allowing a provider or practice to easily identify any variance from expected billing patterns.
These reports should paint a clear and visible picture, providing valuable insight. In the event a CBR is received the reporting can be used as part of the examination and subsequent monitoring following education on the error. Reports can also be supplied to coding/auditing or Clinical Documentation Improvement Departments as a resource to begin analysis for targeted internal education.
Taking a proactive approach to billing patterns can effectively decrease billing errors, support operational excellence and allow providers to spend more time focusing on patient care, which is the heart of pMD’s mission.
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