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Management
Medicare Compliance
Training Handbook
Denials
Management
Training
Handbook
ISBN: 978-1-68308-147-0
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Tracking Outcomes..................................................................... 35
Identifying and Correcting Internal Root Cause Issues............... 35
Understanding Denials
Denials management is a frequent discussion topic among revenue
cycle professionals. Yet despite the continued focus, most industry
statistics reveal that, on average, providers write off between 3%
to 5% of their net revenue to denials every year. These providers
are not ignoring their denials; in fact, most would likely say they
have a denials management process in place. However, few have
a program that not only tracks and trends denials but also uses
that data to identify the root causes of their denials or takes the
necessary corrective actions to prevent them from occurring in the
future. Without such a program, the revenue bleed will continue
to repeat itself year after year.
longer occurring, they will stop auditing those claims. While they
may shift their focus to other areas, if you take the necessary steps
to move your organization from one that merely manages denials
to one that proactively identifies and prevents them, you will stay
one step ahead of the auditors.
•• Length of stay
•• Service provided
•• Level of care
•• Lack of authorization
Technical denials
Any nonclinical denial can be categorized as a technical denial.
Technical denials are also known as preventable denials. Causes
of technical denials can range from contract terms and/or language
disputes, coding-related errors, data entry or registration errors,
charge entry errors, and charge data master (CDM) errors. Other
technical denials may be caused by claims submission and follow-
up deficiencies and denials pending receipt of further information,
such as medical records, itemized bills, an invoice for an
implantable device or drug, or receipt of the primary explanation
of benefits (EOB) for a secondary payer claim.
Coverage/plan denials
The majority of coverage or incorrect plan denials are the result of
process failures during the registration of the patient’s account.
These denials include:
Regulatory Impacts
Regulatory statutes
Regulatory statutes are a large contributor of denials due to an
increased focus on fraud and abuse. The Health Insurance
Portability and Accountability Act (HIPAA) of 1996 established a
national healthcare fraud and abuse program, which has led to the
introduction, or ramping up, of a number of federal and state audit
programs, such as CMS’ RAC program (CMS, Medicare Fee for
Service Recovery Audit program, 2016), CERT program (CMS,
Comprehensive Error Rate Testing, 2016), ZPIC (MLN Matters,
2012), the Medicaid Integrity Program’s (MIP) Audit Medicaid
Integrity Contractors (Audit MIC) (CMS, Medicaid integrity
program, 2015), the Payment Error Rate Measurement (PERM)
audits (CMS, Payment error rate measurement, 2016), and the
Office of Inspector General (OIG) (OIG, 2016) just to name a few.
Each of these programs has unique nuances regarding their scope
CMS guidelines
CMS publishes coverage determinations for items and services at
both a local and national level. While the majority of these are
local coverage determinations (LCD), occasionally CMS determines
the need to publish a national coverage determination (NCD),
which applies to all Medicare providers regardless of their Medicare
Administrative Contractor (MAC). Compliance with both applicable
MAC-published LCDs and the NCDs is a critical element for a
provider to effectively manage and prevent denials for Medicare
and Medicare Managed Care claims. Each MAC will publish a
database containing open (current) and closed (archived) LCDs on
their respective websites (CMS, NCDs Alphabetic Index, 2016).
a. Cost sharing
Compliance with the NOTICE Act and the MOON requirement will
likely prove to be the source of future probes and/or audits by
CMS. Failure to produce a countersigned copy of the completed
MOON form for an observation claim spanning more than 24 hours
upon request would find the hospital in violation of the NOTICE
Act. Hospitals must ensure that they have developed policies and
procedures to incorporate accurate and timely completion of the
MOON form into their processes for observation cases spanning
more than 24 hours for both Medicare-fee-for service and Medicare
Federal guidelines
A number of federal guidelines contain language that directly
impact provider billing. Sometimes, this language may exist as a
subsection of a law that, on the surface, has little to do with
medical billing or beneficiary rights and limitations. Organizations
that are unaware of the full scope of federal guidelines put
themselves at an unnecessary risk of increased denials and
noncompliance.
State regulations
Managed care denials are complicated by the division of financial
responsibility. In some cases, the service is the financial responsi-
bility of the health plan, and in others it’s the responsibility of
the medical group. One of the largest issues contributing to
managed care denials is the failure of the provider/facility to
provide timely notification to the plan or medical group of an
While the regulations cited above are specific to the state of Cali-
fornia, there may be similar statutes in other states. I encourage
readers to research and understand their own state regulations and
not to accept a payer or medical group’s denial in blind faith.
References
Centers for Medicare & Medicaid Services (CMS). (2016). Medicare fee for service
recovery audit program. Retrieved from www.cms.gov/research-statistics-data-and-
systems/monitoring-programs/medicare-ffs-compliance-programs/recovery-audit-program/.
CMS. (2012). The role of the zone program integrity contractors (ZPICs), formerly the
program safeguard contractors (PSCs). MLN Matters, SE1204. Retrieved from www.cms.
gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/
downloads/SE1204.pdf.
CMS. (2014). Recovery auditing in Medicare for fiscal year 2014. Retrieved from
www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-
Compliance-Programs/Recovery-Audit-Program/Downloads/RAC-RTC-FY2014.pdf.
CMS. (2015). Medicaid integrity program. Retrieved from www.cms.gov/Medicare-
Medicaid-Coordination/Fraud-Prevention/MedicaidIntegrityProgram/index.html?redirect=/
medicaidintegrityprogram/.
CMS. (2015). National program total corrections. Retrieved from www.cms.gov/Research-
Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/
Recovery-Audit-Program/Downloads/National-Program-Total-Corrections.pdf.
CMS. (2016). Comprehensive error rate testing. Retrieved from www.cms.gov/
Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-
Programs/CERT/.
CMS. (2016). Details for title CMS-10611. Retrieved from www.cms.gov/Regulations-and-
Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10611.html.
CMS. (2016). National coverage determinations (NCDs) alphabetic index. Retrieved
from www.cms.gov/medicare-coverage-database/indexes/ncd-alphabetical-index.
aspx?bc=AgAAAAAAAAAAAA%3d%3d&.
CMS. (2016). News & announcement. MLN connects provider enews. Thursday, November
3, 2016. Retrieved from www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/
Provider-Partnership-Email-Archive-Items/2016-11-03-eNews.html#_Toc465834795.
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