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Office of Medicaid (MassHealth) - Review of Evaluation and Management Claims Paid to Lawrence Family Doctors

August 16, 2017 · Office of Medicaid (MassHealth) · Read the full official report (PDF) ↗ · official site ↗

Published August 16, 2017 Audit covers January 1, 2011 – June 30, 2016 Under Suzanne M. Bump · 2011–2023

In plain English
The audit found that Lawrence Family Doctors billed MassHealth incorrectly for nurse practitioner visits and lacked proper records for some services, leading to at least $108,232 in overpayments plus $2,316 tied to documentation problems.
source
“LFD improperly billed MassHealth for at least $108,232 of E/M services provided by NPs.”
Read the plain-English breakdown
What is this?

This is a Massachusetts State Auditor performance audit of MassHealth payments to Lawrence Family Doctors for evaluation and management services from January 1, 2011 through June 30, 2016.

“OSA has conducted an audit of evaluation and management (E/M) claims paid to Lawrence Family Doctors (LFD) for the period January 1, 2011 through June 30, 2016.”
Why was it audited?

The auditor reviewed this provider because MassHealth spends heavily on these kinds of medical visit claims, and earlier audits had found possible improper billing in this area.

“Because of the significant amount of these expenditures, as well as prior OSA audits that identified potential improper billings for E/M services, OSA is continuing to audit this type of claim.”
Why it matters

Incorrect billing can waste public Medicaid money and reduce public confidence in MassHealth.

“As with any government program, public confidence is essential to the success and continued support of the state’s Medicaid program.”
What's in it for me?

If you are a Massachusetts taxpayer or MassHealth member, this audit is about whether public healthcare dollars were paid correctly and whether patient records supported the care billed.

“MassHealth provides access to healthcare services to approximately 1.9 million eligible low- and moderate-income children, families, seniors, and people with disabilities.”
The bottom line

The auditor concluded that Lawrence Family Doctors did not properly bill MassHealth for nurse practitioner services and should repay the identified overpayments.

“LFD should collaborate with MassHealth to establish a plan to repay the $108,232 in overpayments it received from improper E/M service billings.”
What happens next

The report recommends that Lawrence Family Doctors repay MassHealth, bill nurse practitioner services correctly going forward, review billing rules, and improve medical record access and documentation.

“LFD should bill for NPs’ services using either the SA modifier or NPs’ servicing provider identification numbers.”
Why it's significant

The issue is significant because the audited provider received more than $1.2 million from MassHealth for these visit-related services during the period reviewed, and the auditor projected a high error rate in the claims tested.

“During this period, LFD was paid approximately $1,233,444 to provide E/M services for 1,763 MassHealth members.”
Jargon, unpacked

E/M means routine medical evaluation and management services, such as office visits, and NP means nurse practitioner.

“Based on the American Medical Association’s Current Procedural Terminology Professional Edition 2014 (CPT Codebook), E/M services are divided into broad categories such as office visits, hospital visits, and consultations.”
Identified in this audit - source-verified
$110,548

What the Auditor checked

What the Auditor found

Lawrence Family Doctors improperly billed MassHealth at physician rates for services provided by nurse practitioners.
vendor oversightinternal controls

Why it matters: MassHealth overpaid at least $108,232 that could have been allocated to Medicaid or other state benefit programs.

Standard: MassHealth regulations require claims to be submitted by the provider that rendered the service and require modifier codes for services performed by non-independent nurse practitioners. ( Section 450.301(A) of Title 130 of the Code of Massachusetts Regulations; 101 CMR 317.03(4); 101 CMR 317.04(3) )

3 recommendations
  • LFD should collaborate with MassHealth to establish a plan to repay the $108,232 in overpayments it received from improper E/M service billings.
  • LFD should bill for NPs' services using either the SA modifier or NPs' servicing provider identification numbers.agency: already implemented
  • LFD should periodically review MassHealth billing requirements and updates and ensure staff follow them.agency: agreed
Agency response & Auditor reply
Agency: "We are now billing visits provided by NPs with an SA modifier."
Auditor: "However, MassHealth regulations specifically require its providers to bill using the SA modifier in all instances when NPs provide services to MassHealth members, even when the supervising physician works with the NPs on establishing a care plan."
Lawrence Family Doctors did not maintain proper documentation for some evaluation and management services.
recordkeeping/documentationinternal controls

Why it matters: Incomplete records raise concerns about whether billings were proper and can negatively affect continuity of patient care.

Standard: MassHealth regulations require providers to maintain records sufficient to document the nature, extent, quality, and medical necessity of services. ( 130 CMR 433.409(B); 130 CMR 450.205(A); 130 CMR 433.409(D)(1) )

2 recommendations
  • LFD should maintain necessary documentation to support the nature, extent, and medical necessity of care, including exams, medical histories, and chief complaints.agency: agreed
  • LFD should ensure it can retrieve all medical records stored on computer servers.agency: agreed
Agency response & Auditor reply
Agency: "We will ensure that LFD maintains proper documentation for all E/M services."
Auditor: "As a MassHealth provider, LFD is required to take the measures necessary to ensure that its records are maintained in accordance with these regulations, including making sure it can promptly retrieve medical records from any storage device used to store this information."

Verified dollar findings

Improper payments identified $110,548

Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.

$108,232 - overpayment
$2,316 - overpayment

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