AAHC Responds to HHS and DOJ Letter; Calls for Clarification on Guidance

WASHINGTON, Sept. 25, 2012 /PRNewswire-USNewswire/ -- Dr. Steven Wartman, Association of Academic Health Centers (AAHC) President and CEO, along with five healthcare associations received a strongly worded letter yesterday from HHS Secretary Kathleen Sebelius and Attorney General Eric Holder.

The letter raises concerns about reports on the use of electronic health records to improperly bill for services not provided and "upcode" services to receive higher payments than are warranted. It indicates that "misuse" of electronic health records will be aggressively monitored, audited, and prosecuted to the fullest extent of the law

"It goes without saying that AAHC and our members do not condone fraud," said Dr. Steven Wartman, AAHC President and CEO. "But being aware of improper billing alone doesn't solve the issue. Clarification on evaluation and management services coding has been a priority for AAHC, and we are ready and willing to work with the Centers for Medicare and Medicaid Services and our members to address this issue."

In response to Secretary Sebelius and Attorney General Holder's letter, AAHC issued a response letter commending CMS' efforts to take action on waste, fraud and abuse, but also asking for assistance and clarification on CMS' guidelines and oversight of the contractors CMS hires to do Medicare audits.

AAHC's Forum on Regulation, comprised of chief compliance officers at academic health centers, had previously expressed concern about the availability of clear and useful guidance on the coding of evaluation and management services.  Those concerns have only been exacerbated by the increased uptake of electronic health records and the rapid changes in the delivery system necessary to accommodate more sophisticated technology. 

Also, CMS will be conducting audits to prevent improper billing and "initiating more extensive medical reviews to ensure that providers are coding evaluation and management services accurately."

"We support and understand the need for CMS to conduct audits to identify instances of improper billing, both intentional and inadvertent," added Wartman. However, AAHC expressed concerns regarding the system of incentives for and oversight of Medicare Recovery Audit Contractors (RACs).

In addition to asking for clarification on CMS' guidelines, AAHC also asked that CMS' Center for Program Integrity expand its risk-based assessment tools for the prevention of fraud, waste, and abuse to the work of the RACs.

The Association of Academic Health Centers (AAHC) is a non-profit organization that seeks to advance the nation's health and well-being through vigorous leadership of the nation's academic health centers.Representing more than 100 academic health centers nationwide, AAHC is dedicated to improving the nation's health care system by mobilizing and enhancing the strengths and resources of the academic health center enterprise in health professions education, patient care, and research. The membership comprises all the health-related components of a university, including health professions schools (e.g., medicine, nursing, dentistry, public health, pharmacy, and others), biomedical and clinical research programs, and a teaching hospital or health system.   

Contact: Mindy J. Steinberg, 202-265-9600

SOURCE Association of Academic Health Centers

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