In the second example in recent months of a Medicare Advantage
insurer disputing the federal government’s method of identifying overpayments,
a new HHS Office of Inspector General audit report limited its review to a
group of diagnosis codes that it maintained are at a particular risk for being
miscoded.
Conducted separately from CMS's contract-level Risk Adjustment
Data Validation (RADV) audits that verify the accuracy of payments made to MA
organizations, the recent findings are part of a series of audits in which OIG
is reviewing the accuracy of diagnosis codes submitted to CMS. In a similar
report released in April, OIG estimated that Humana Inc. received nearly $200
million in net overpayments for a contract serving approximately 485,000
enrollees.
In the May report, OIG recommended that Anthem repay the federal
government $3.47 million for net overpayments related to a group of
"high-risk" diagnosis codes, referring to certain disease categories
that are prone to miscoding. OIG identified seven disease groups that have an
elevated risk of being miscoded: acute stroke, acute heart attack, acute stroke
and acute heart attack combination, embolism, vascular claudication, major
depressive disorder, and potentially "mis-keyed" diagnosis codes.
OIG suggested that these coding inaccuracies were due to
Anthem's inadequate procedures to detect and correct noncompliance. In a
statement emailed to AIS Health, Anthem maintained that it complied with MA
regulations when submitting the diagnosis codes in question and pointed out that
OIG "did not identify any specific deficiencies in our programs through
its audit."
Kirk Martindale, vice president of the data audit group within
ATTAC Consulting Group, says it is imperative that MA plan sponsors have robust
medical record review and audit procedures in place, particularly around those
high-risk diagnosis code groups, to ensure that the codes they submit to CMS
are accurate and can be backed by medical record documentation.
Similar to Humana, Anthem did not agree with OIG's findings and
recommendations. Among its gripes, the insurer argued that the report: included
inaccurate findings specific for major depressive disorder and embolism, relied
on "sampling and review methodologies that are improperly skewed toward
identifying 'overpayments,'" and used a lower confidence interval that is
not as statistically sound as the higher interval used by CMS in its RADV
audits.
OIG, however, disputed Anthem's characterization of its net
overpayment calculations as skewed and biased and maintained that it used a
statistically valid sampling methodology.
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