The Triple Check System as a Means of Avoiding Billing and Coding Errors
Louise Lindsey, Editor
Using a Triple Check Process is the easiest way for Skilled Nursing Facilities to verify the accuracy of all inputted data prior to submission of claims to Medicare. The Triple Check Process will also ensure that residents receive the treatment and care to which they are entitled, and that all clinical documentation correlates with financial data.
In order to carry out a complete Triple Check Process, representatives from the Business Office, the Therapy Department, the Nursing Department, the Minimum Data Set (MDS) Coordinator, the DON, ADON, or designated Clinical Manager, and the Administrator, Chief Financial Officer, or Chief Operating Officer should be involved.
The Business Office representative must investigate and verify that the resident has Medicare benefit days available; that the qualifying stay listed on UB-04 corresponds with medical record dates, and confirm that the census log admit date agrees with the UB-04 date.
In addition, standard verification procedures should be in place in the Business Office to verify the accuracy of the resident’s name, social security number, and Medicare number. It should also ensure that vendors do not bill Medicare directly for items included in the facility’s required consolidated billing, such as laboratory, radiology, pharmacy, and equipment.
Other procedures which have to be verified by the Business Office include a check that the Medicare Secondary Payer (MSP) form is signed, dated, as appropriate, when the patients/residents are working age Medicare beneficiaries covered by an Employer Group Health Plan; and that all relevant insurance coverage, where applicable, is valid and in place.
The Therapy Department must verify that all therapy minutes recorded in the daily treatment grid agree with the service log, and that principle and secondary diagnoses are listed accurately.
The Nursing Department must ensure that all documentation supports Medicare skilled interventions during the dates of service which correspond with the census log; that any physician certification/recertification form is completed and signed by the ordering physician; that physician orders are received and implemented; and that charting is completed at least once every 24 hours.
The MDS Coordinator must ensure that the Resource Utilization Groups (RUGs) level of each MDS agrees with the UB-04; that the number of accommodation units agrees with the covered dates of service; that the Activities of Daily Living (ADLs) are correctly entered and supported by documentation; and that all International Statistical Classification of Diseases and Related Health Problems (ICD-10) codes are correct and correspond to diagnoses.
The Administrator or CFO/COO will chair the Triple Check Meeting, ensure that that all participants complete their checks prior to any claims submission, and monitor the effectiveness of the interdisciplinary team interactions.
During the actual Triple Check meeting, time should be spent verifying and cross-checking each Medicare claim, and any final verifications and cross-checks should be completed by someone other than the person who originally recorded the information being confirmed.
Using this system will certainly weed out all but the most obscure—or deliberately fraudulent—data entries. Apart from the obvious benefit of reducing the number of rejected claims, a Triple Check Process will also reduce the facility’s exposure to damaging Office of the Inspector General (OIG) investigations and penalties.
