E/M Coding Alert - 2004 Issue 14
COMPLIANCE: CERT Slip Will Bring You OIG Attention
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Article Overview
This compliance-focused article explains how CMS and its contractors handle delayed or unanswered CERT medical record requests and why the process has drawn criticism. It is relevant to providers, billing and compliance staff, and other Medicare stakeholders who track record-request workflows, contractor outreach, and oversight activity tied to payment error rate reporting.
Why This Topic Matters
Understanding CERT follow-up procedures helps providers and compliance teams recognize the operational and oversight risks associated with delayed responses to medical record requests. The article also places those procedures in the broader context of CMS error rate reporting and OIG involvement.
Article Sections
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Non-response to CERT record requests
Introduces the issue of delayed responses to contractor medical record requests and the concern that follows when providers do not reply promptly.
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CMS oversight and error rate reporting context
Describes CMS involvement in Medicare payment error rate reporting and the broader reporting context surrounding CERT activity.
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Carrier and intermediary follow-up actions
Summarizes the timing and types of follow-up contacts CMS expects contractors to make when records are not received.
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Referral to regional OIG staff
Explains the escalation path discussed in the article when the requested records are still not received after contractor and carrier follow-up.
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Criticism of the process
Covers the concerns raised about how the request process is communicated and the impact on providers who do not respond in time.
What You Will Learn
- How CMS and contractors respond when CERT record requests are not answered
- How CERT activity fits into Medicare error rate reporting
- What kinds of follow-up and escalation are described in the article
- Why the process has generated criticism from providers and observers
Who Should Read This
- Medical coders
- Billing staff
- Compliance officers
- Revenue cycle professionals
- Medicare providers
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