Liles Parker PLLC
(202) 298-8750 (800) 475-1906
Washington, DC | Houston, TX
San Antonio, TX | Baton Rouge, LA

We Defend Healthcare Providers Nationwide in Audits & Investigations

MIC Dental Audits: Are Your Dental Practices Compliant?

(July 11, 2012): For many years, government fraud and abuse contractors have focused their efforts on primary care physicians, hospitals, DME suppliers, and other Medicare providers. During this period, these contractors, such as ZPICs and RACs, largely ignored auditing claims from dental providers. Additionally, dental audits by private payors, while they do exist, are few and far between. Unfortunately, times have changed for dentists and orthodontists. Dental audits of Medicaid claims are currently on the rise by Medicaid Integrity Contractors (MICs) and Medicaid Recovery Audit Contractors (MRACs), as well as federal and state Offices of Inspector Generals (OIG).  At this time, most of the audit activity we are seeing is being conducted by MIC program integrity contractors.  As MIC dental audits increase in your state, it becomes especially important that you understand and comply with all applicable regulatory requirements.

I.  CMS is Now Focusing Resources on MIC Dental Audits:

The Centers for Medicare & Medicaid Services (CMS) contracts with various private companies to perform dental audit functions. These companies, such as MICs or MRACs, then have financial incentives to ferret out as much fraudulent and wasteful billing as possible. Like ZPICs and RACs, MICs and MRACs are experienced, sophisticated, and aggressive when it comes to auditing Medicaid claims. With their current focus on dental audits, providers of these services should be aware of some important information about dental audits and appeals.

II. Considerations When Handling MIC Dental Audits:

If your Medicaid dental claims are under audit or investigation, it is important to know your rights and responsibilities. Above all else, keep in mind any established deadlines. While many issues can be argued on appeal, missed deadlines cannot. If you receive a request for records or a demand letter, it is important to identify the relevant time frame you are working under and make sure you respond timely. Also consider retaining an attorney who is experienced and knowledgeable in this area. Dental claims coding and billing are complex and require a high degree of precision and accuracy. You should find a representative who is not just comfortable, but fluent in Medicaid dental guidelines. Attorneys and other representatives should have staff with understanding of Medicaid billing, and keep in mind that Medicaid appeals guidelines can, and often do, vary from state to state. Because of this, make sure you retain someone with demonstrated expertise in these appeals.

III.  FInal Remarks:

Finally, as a preventative measure, make sure that your documentation practices are adequate. This means not only that your files identify all of the relevant information needed to pay a claim, but are legible, signed, and completed timely. Like deadlines, improper or missing documentation is a very difficult issue for a provider to overcome. Here, a compliance plan and gap analysis can assist to identify any areas of weakness in documentation and develop an effective corrective action plan.

Healthcare LawyerRobert W. Liles is the Managing Partner at Liles Parker PLLC, a Washington, D.C. based health law firm representing dental professionals and other health care providers around the country.  Robert represents dental providers in connection with both Medicare and Medicaid post-payment audits and appeals. In addition, Robert counsels dental clients on regulatory compliance issues, performs gap analyses and internal reviews, and trains dental professionals on various compliance and legal issues. For a free consultation, call Robert today at:  1 (800) 475-1906.

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