Medicare Improper Payment Report for Behavioral Health Services (2019)

by  Jared Staheli

CMS audits claims on an annual basis to identify improper payments. These improper payments do not measure fraud. Rather, they estimate the share of payments that did not meet Medicare coverage, coding, and billing rules. In the most recent Improper Payment Report, behavioral health services have some of the highest Part B improper payment rates, shown in the table below.

 Type

2018 Improper Payment Rate

2019 Improper Payment Rate

Type of Error

No Doc

Insufficient Doc

Medical Necessity

Incorrect Coding

Other

Clinical Social Worker 16.6% 21.4%

4.5%

91.0%

0.0%

2.0%

2.5%

Clinical Psychologist 23.5% 24.4%

0.0%

100%

0.0%

0.0%

0.0%

Psychiatry 23.9% 14.3%

0.1%

59.3%

0.0%

39.1%

0.0%

Insufficient documentation remains the primary reason for improper payments, though for psychiatiry, incorrect coding made up a substantial share of error. A careful review of Chapter 4 — Documentation in the 2021 Reimbursement Guide for Behavioral Health can provide guidance on how to properly document services provided.

References:

Medicare Improper Payment Report for Behavioral Health Services (2019). (2020, October 12). Find-A-Code Articles. Retrieved from https://www.findacode.com/articles/medicare-improper-payment-report-for-behavioral-health-services-2019-36718.html

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