Talk of The Villages Florida - View Single Post - Potential Fallout - Beyond Healthcare - of TVHC's Massive Medicare Overbilling
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Old 08-19-2025, 10:49 AM
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Originally Posted by Justputt View Post
The wording below by Luria is vague enough "did not appear to be supported by a sufficiently documented clinical basis" that this could be more about a lack of documentation than incorrect entries. We won't know until there are more details presented. I also wonder how much this has to do with the changes made in 2018, 2021, etc. regarding documentation and whether the entire staff kept up with the changes. I know from nearly 40 years in radiation oncology there are more than a small number of people that have different options on coding matters.
Outpatient E/M Coding Simplified | AAFP

Lastly, in the physician groups I've worked with, they not only selected the ICD code, but they also itemized the codes that would be charged (both for pre-auth and giving the patient their good faith estimates for care) as well as dictated the documentation justifying all charges.

"TVH Chief Restructuring Officer Neil Luria said in a July 3 court filing that last year the company hired outside law firms and FTI Consulting Inc. to evaluate the accuracy of the health-care provider’s coding and to investigate any potential over-payments related to Medicare.

That investigation “identified codes TVH submitted that did not appear to be supported by a sufficiently documented clinical basis,” Luria said. The inquiry also identified amendments to patient medical records “appear to have been inconsistent with [the Centers for Medicare and Medicaid Services] guidance and based on a misunderstanding of the relevant guidance on medical record amendments, including when it is appropriate to amend a patient record more than 90 days after an encounter,” he said."
Now that post I pretty much agree with. And therein lies the problem---rules and guidelines that are subject to interpretation. Always a formula for problems. When you get caught driving 50 in a 35 zone, the facts are the facts. When the law specifies a mandatory $300 fine, that's it. But when you use the ICDM-10 code for "former smoker", it opens a whole can of worms---how many years smoking?, how long ago did they quit?, how many packs/day?, any COPD?, any thin section chest CT indicated?, how often?. And they key question: Was it "documented". Bottom line: a thousand thing happen in a routine office visit and nobody can "document" them all, which leads to the secondary issue----the idiotic assertion forced on the medical profession by bureaucrats, lawyers and insurance companies---if it wasn't written, it didn't happen. NONSENSE. I shaved this morning. I didn't write it down, so therefore I didn't shave???

So, bottom line, all the hoopla comes down to who wrote what, who interpreted which guideline correctly, which reviewers and bureaucrats are involved and whether or not there was any intent involved.

Everyone seems to want a crucifixion, except maybe the people who are alive and well today because of TVH.