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Did you know that physicians “copying and pasting” in their EHRs, sometimes referred to as EMR cloning, has resulted in Medicare and other insurance companies denying payments? These denials then invite case reviews, audits and even new legal liabilities. Independent Medicare Administrative Contractors (MAC) who review charts for appropriateness of service have been directed by the Centers for Medicare and Medicare Services (CMS) to identify “suspected fraud, including inappropriate copying of health information” under the Benefit Integrity/Medical Review Determinations mandate.
MACs have started to deny payments on the grounds that cloning is a “misrepresentation of the medical necessity required for services rendered.” This is an absence of explicit, individual information. One MAC has established policies for its reviewers to assure that medical necessity of services includes documentation demonstrating that physician notes are different and not merely a copy of the initial history and physical entry.
The Center for Government Services (CGS) states “For Medicare, the medical necessity of a service is the overarching criterion for payment, but necessity is considered fraudulent if cloning of past medical services, lab and x-ray results, and medical notes from previous days are simply reinserted into a new day’s progress note to justify need.”
This webinar will provide you with the information you need to reduce the risk that cloning or clinical plagiarism could cause your practice.
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American Osteopathic Association
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Speaker: Jill Young, CPC, CEDC, CIMC