WP97 | Why Insurance Audits are on the Rise and How to Steer Clear with Tracy Greig
In this episode of the Wise Practice Podcast, host Whitney Owens interviews Tracy Greig, owner of Twin Oaks Medical Management, who brings over 35 years of experience in medical management. Tracy shares valuable insights into the increasing prevalence of insurance audits, the role of AI and robust algorithms in catching claim errors, and the importance of proper billing, coding, and compliance. She explains the intricacies of navigating insurance contracts, particularly for telehealth services, and offers advice on handling audits to avoid financial repercussions. Tracy also discusses the ethical considerations in couples therapy within insurance-based practices. Listeners will gain practical strategies to ensure regulatory compliance and maintain the integrity of their practice.
The Rise of Insurance Audits
One of the main points Tracy highlighted was the increasing prevalence of insurance audits. With advancements in artificial intelligence (AI) and more robust algorithms, insurance companies are detecting billing errors faster than ever before. Tracy emphasized that providers must be vigilant with their coding practices, especially when it comes to documenting treatment and coding to the highest specificity.
According to Tracy, mental health providers are particularly at risk for audits. This trend began during the COVID-19 pandemic, when telehealth became more widely used, resulting in a significant uptick in insurance fraud. As a result, mental health practitioners have become a primary focus for insurance companies, particularly those working exclusively in telehealth. Tracy noted that providers who do not offer patients the option to choose between in-person visits and telehealth services may face difficulties securing insurance contracts in the future.
The Impact of AI on Chart Notes
While AI can be a useful tool in private practice, Tracy warned that it is essential for providers to carefully review their AI-generated chart notes. She shared an example where AI had misinterpreted patient information, leading to discrepancies that could have serious consequences during an audit. Tracy stressed that ultimately, the responsibility lies with the provider to ensure that chart notes are accurate and reflective of the care provided.
Couples Counseling and Insurance
Another important topic discussed in the podcast was the issue of billing for couples counseling in insurance-based practices. Tracy explained that insurance companies typically do not cover marriage therapy, which poses challenges for therapists who may be treating couples but are billing insurance under one partner’s name. She advised that it is crucial to identify which individual is the primary patient and ensure that charting reflects that distinction. If both partners require therapy, the other individual should be referred to a separate provider to avoid conflicts of interest and potential issues with insurance.
What to Do if Audited
So, what should a practice owner do if faced with an audit? Tracy offered practical advice:
Review the Audit Letter: Carefully examine the letter you receive from the insurance company. This will give you an understanding of the scope of the audit.
Hire an Auditor: Consider bringing in an outside auditor to review your chart notes and help you navigate the audit process.
Seek Legal Counsel: If the situation is severe, consult with an attorney who specializes in healthcare law. It’s important to protect your practice and ensure that all responses to the audit are handled properly.
Tracy shared a story from her own experience, where she successfully helped a provider avoid paying back a significant sum to an insurance company by challenging the audit's basis. This underscores the importance of being proactive and seeking expert assistance when necessary.
As the healthcare landscape continues to evolve, mental health providers must stay informed about the latest trends in compliance and insurance regulations. Tracy Greig’s insights on the Wise Practice Podcast serve as a valuable resource for practitioners looking to protect their practices and navigate the complexities of billing, coding, and audits.
For those in the mental health field, taking the time to review contracts, understand billing codes, and ensure compliance is more critical than ever. As Tracy mentioned, staying ahead of these issues can save you from costly audits and keep your practice running smoothly.
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Whitney Owens: Well, welcome to the podcast. So glad that you're with us. And I'm here to introduce you to my guest, Tracy Gregg. She is the owner of Twin Oaks Medical Management. She started the business 35 years ago and has grown it to what it is today. She oversees all business decisions and operations. And with her years of experience, she understands what it is to be a business owner.
And how the bottom line affects the entire business and your practice. Customer service is important to her. It shows through her trainings and leadership. She started Twin Oaks management, medical management, working with mental health professionals throughout Oregon. And now she's throughout the United States, including Alaska and Hawaii and New Mexico, working with all providers and disciplines, providing billing, coding, audits, practice management, credentialing, contracting, clinic startup.
compliance and revenue enhancement. Tracy's also actively involved in the AAPC and the NCT organizations as well as being active in her church. She has a son, daughter in law, five grandchildren whom she loves spending time with. She enjoys cooking, baking, gardening, public speaking, and traveling. Tracy, thank you for coming on the show.
Thank you, Whitney, for having me. Yeah. And when we met, I don't know, a couple of months ago online, I was like, man, Tracy knows her stuff, you know, when it comes to business and when it comes to especially insurance, credentialing, billing, and I can see your passion for wanting to help people. So I'm really glad to have you on the show today.
Thank you. Yeah. Yeah. So we were talking about what is going on with insurances and all the things audits. Audits are becoming a lot more prevalent. And so can you kind of share with us, start out with what's going on? Why is this happening?
Tracy Greig: Audits are happening more and more. Insurance companies are becoming more robust in their algorithms.
AI is becoming more and more prevalent in our health care industry. So between the robust systems that all the insurance companies have working in the algorithms and working with AI, they are capturing claim errors. And billing much more quickly. So if providers are not coding to the highest specificity, if they are seeing continuous care time and time again over months, and there's no break in care in patients, and they are not seeing improvements in the patients, the insurance companies are really looking that providers are there to profit their pockets instead of helping them.
Even though that may not be true, that's how the insurance companies look at it. So that is a good window of opportunity for the insurance companies to come in and start requesting your chart notes and looking at everything. Once they have your chart notes, then they're looking at the complexity of your chart noting.
Are you chart noting in a way that is consistent with the way you are billing. And if they are seeing discrepancies, then they send, send that over to their auditing team to take a closer look at it. And we're seeing larger rises on takebacks by the insurance companies. And they're saying that chart notes do not meet the specificity of their billing.
So it's a really important in the aspect, if providers are doing their own billing to understand what those rules and regulations are and the compliance surrounding that billing and coding,
Whitney Owens: that's a lot. It is that's already a lot to keep up with. Yeah. Are you seeing any themes as far as certain types of practices that are more likely to get audited right now, or the size of your practice or certain types of insurances that are more common to get audited.
Tracy Greig: Not a difference in the insurances. I would say if you wanted to break that down, Wendy, in insurances, the Medicaid, the federal government, and the state regulatory bodies are coming together more so in looking at the Medicaid, because those are both federally funded. federally and state funded programs, and anytime you're dealing with a federal agency, they really look heavy into that insurance fraud because they are a more robust entity to be able to look and research that maybe more so than a commercial carrier.
But right now, nationwide, mental health providers are the number 1, group or practices that are being audited because they were the highest risk during COVID when they were doing telehealth services and they saw about a 45 percent uptick on insurance fraud. So they are looking in on that. They are also looking where more providers are wanting to do exclusive telehealth and work in their home and they are starting to see more suicides because Providers are not able to see all of the body language of the patient or the client case, whether you're a psychologist or a psychiatrist or a counselor.
That's why I refer to patients and clients, and so insurance companies are having more mandates by the federal government and state regulatory. Entities to really come in and take a look at that, and they are finding that. If patients don't have a right to choose whether they can come to a brick and mortar clinic or do telehealth, they are starting to say that they're not going to provide contracts for those providers.
So, it's really important, I would say, with the regulatory rules and the compliance surrounding everything right now, Whitney, that providers have the ability to offer. And what we're doing right now in Oregon, really big. For those practitioners who want to have the telehealth, we are setting up areas in our office where they can come in and we have one office and they can coordinate different days with providers.
So we're opening up a couple of our offices in my practice where they can come in and just rent the space. Similar to what we see across the nation in commercial business areas where everybody can go in and rent a desk. Unfortunately, mental health and medical providers cannot do that. They need behind the closed door.
That is one thing I would say clear across the United States with practitioners. If they have colleagues that they don't work on a Thursday or they don't work on a Friday, they start pulling their resources together in those brick and mortar buildings.
Whitney Owens: Mm hmm. Yes. So you're saying therapists that are doing telehealth and taking insurance are more likely to get audited than in person therapy.
Tracy Greig: I wouldn't say it's more likely 1 over the other what they are looking at when it comes to getting insurance contracts. If providers are exclusive telehealth, it is getting much harder to get contracts for exclusive telehealth services.
Whitney Owens: Do you feel like it's getting harder just in general to get contracts because of what's going on?
Tracy Greig: I believe it is getting harder. I mean, I've been in the industry a lot of years, so when I started out, contracts were one page. Now we look at contracts being 47 to 52 pages, and there is a lot of Regulatory language in those contracts that is really protecting the insurance companies. And if providers are not negotiating those contracts and paying attention to that language, it definitely can trip them up and leave them wide open for audits.
Whitney Owens: Mm hmm. Definitely. You definitely want someone that knows their stuff to be looking at those contracts. That's for sure.
Tracy Greig: That's right. And not just signing contracts, Whitney, but really negotiating them because that is the number one thing I hear is Tracy, why am I paying you the money that I pay you to do my credentialing and contracting?
And I ask them, do you understand the regulatory rules around contracting? No, but can't be that hard to understand. And then I say, do you understand compliance? And then Do you understand how to negotiate contracts? And I talked to them a great deal Whitney about not just looking at negotiating for price, while that is something you need to look at, but negotiate that language in those contracts.
A lot of contracts will say, if you haven't filed your claims in 30 days, you still have to file, but we're not going to pay you. What, what's happening, you know, if Providers have associates in their practice and the providers have a full caseload and they're having to sign off and read those associates chart notes.
Can they get them turned around and get them either to their biller or get them billed out their self quick enough. Those are things to really watch in the language of your contracts.
Whitney Owens: Mm hmm. Definitely. So, so going back to the auditing and you kind of mentioned some of this already, are there commonalities maybe that you haven't mentioned yet?
I just want to make sure we get them all that you're seeing as far as reasons people are getting audited that they need to be aware of.
Tracy Greig: Yes. The add on codes is a big portion of it.
Whitney Owens: Yes.
Tracy Greig: So providers not documenting their in and out time within their chart notes. So Tracy comes in to see Whitney at 8 a.
m. And she checks out at 9 o'clock and providers are feeling they are going to not just use like the 908 37 or whatever. They're also going to do an add on code. What providers aren't realizing is those add on codes are not just complexity add on codes. Those are also time based codes. So I'm seeing when I go in, Debbie and I, and we are doing audits.
They're just adding those which is going into an algorithm and then insurance companies are coming back saying you don't meet the regulatory requirements. For the time that you're recording, so it's really understanding those CPT codes and I suggest if providers don't have a clear understanding of the business as a whole, and the coding and billing guidelines and rules, and they're not looking at their coding books, or they don't have them in their office.
I really advise them either to hire or outsource their billing, so it will alleviate a lot of pressure. From those providers getting those audits. And in an audit, your practice could be watched for a year or two and you never know they're watching you. And then all of a sudden they will come in and do an audit and then they will start those take backs or clawbacks.
Some people call them.
Whitney Owens: Yeah, you just, I never even heard of that one, the add on part. So that's just one small, not, I mean, I shouldn't say small, but one of many things that people get audited for, I'm sure.
Tracy Greig: Correct. Yep, they look at, we are seeing when chart notes are going in, we were in and on it the other day, and we audited 47 charts in a practice, and it's the language and paying attention to how you're doing your dictation.
If you're doing AI. That's great, but go back and read your chart notes, because as we were reading, some of our comments say, it sounds like the provider was sleeping with the client. They, the person is definitely a female, and they kept referring to he, and when we got to the very bottom, it said dictated by AI.
Well, that's great. AI can help in your practice, but it is still up to that provider to come back. And this practice is, has received an insurance. Chart audit review, not a financial, but a chart audit because they're, they were spot checking and they were trying to make sense of these chart notes and what was going on.
So it's, we don't intentionally try to make those mistakes, but as AI grows in our practices and our businesses, we really need to pay attention and not assume that everything is absolutely accurate. So it's proofreading your chart notes before you sign them off.
Whitney Owens: Yeah, well, I think you brought up a point that I get a lot of questions about is, is it okay to use AI to write my client notes?
You know, can you speak to that?
Tracy Greig: It is okay to use Dragon AI. Again, it comes back to, you are ultimately responsible at the very end when you sign off on those chart notes. So, however, Or whatever tool you're using within your practice, it's going back again and making sure accuracy is there. I go back many years ago when I started into medical before I even opened my own practice.
I was managing clinics and part of my job was to read the doctor's chart notes. Everything was handwritten back then. Everything was on my fish back then, which a lot of people don't understand what that is. And it was really hard. And when you go to trial with the doctor to help fight a case and the attorneys and the judge can not.
Read and understand your chart notes. It's going to be all up to assumptions at that point and how they look at your chart notes and what their own thought process is in what you're trying to say. So, you never want to leave that margin of error open for somebody else to assume what you're trying to say.
And especially when we look at divorces are higher on the rise, custody cases are higher on the rise. We're seeing a lot of gender identity on the rise. And so it's really, really relevant that we all are paying close attention to every minute detail that we're doing in the chart noting.
Whitney Owens: Yeah. All right.
So I do have another question that we've been actually working on in my practice. I'd love to get your thoughts on when couples come for therapy. Yes. Yeah, so what I have noticed as a trend is that insurance based practices are seeing one member of the couple and identifying them as the patient, and then actually treating it like couples counseling.
So I was curious what you thought about that. Is that appropriate or not? Or should you have two files for each person? And is that going to get us in trouble?
Tracy Greig: Here, that question comes up many, many times, and it's a great question, Whitney. And we actually just came back from a conference in Vegas where that really was a big topic in our mental health breakout sessions.
And what the, an insurance auditor said is, you need to identify out of that couple, who is the patient. And that is the person that you're going to be treating. The spouse or the partner coming in could be support, but you should never treat both of them because you cannot be partial to one or the other at that point.
So what the auditor was telling us at our conference is, she said, decide who your patient is. And then if the other person, whether it be a spouse or a partner, needs therapy individually for themselves, have them referred out to another counselor. And then that way, you don't have two different charts.
You can stay neutral, with the person who you're doing care with. Especially what we talked a great deal about is if it's a couple and we're in a divorce situation and it comes to custody. Now what happens is that goes into court. You're, you could possibly be called into court and be questioned for your chart note.
How can you side with one over the other? You're treating both of And so you're trying to give recommendations. to one, and it's really hard for you to stay neutral on both sides.
Whitney Owens: Yeah, I think it's so dicey, right? Because from a clinical standpoint, we see the marriage as the couple relationship as the couple.
So, in my mind, I'm like, I should be charting on that as the client, you know, dynamic, but. You're kind of, I hear what you're kind of saying is this, this insurance auditors saying no treat one like the patient. I guess what would be interesting to me is if the, let's say the man, let's say it's a man and a woman, I'm just being typical here.
Yeah. And let's say the man's the identified client, the woman's not, the woman gets referred up for therapy. What if the man also needs individual therapy? Then he sees somebody else for that?
Tracy Greig: You can, but here's the thing. Insurance companies. As we know, marriage therapy is not covered. Right. So that is why the insurance auditor really talked for three hours to us about, you select who your patient is.
And then you can bring them together as support and just say within your marriage, you know, here, here are ideas that I'm thinking of that could help you, but you have traditional marriage counseling, the insurance company say, go find your church, go find a pastor, find somebody that actually can help you.
If you need true marriage counseling or find a therapist, just don't go ask. And then the patient is responsible for, to pay for that couple's counseling, which is to me, it's unfortunate because if we have healthy boundaries and we have healthy counseling, we're going to have happier couples and happier families and maybe see our divorce rate go down a little bit.
But as I said, in all of my 40 years that I've been doing this. We are governed by the insurance and our government rules and regulations, and the Senate and the House start setting the precedence for that CMS, AMA comes in, they put the guidelines, and unfortunately, whether we agree or disagree, if we're going to have practices, we have to follow their rules and boundary guidelines.
Whitney Owens: Yeah, totally. All right. Well, thanks for answering that question because that's a burning one over here. And so now let's talk a little bit about what to do if I'm audited. So, let's say someone finds out an insurance company is coming in and auditing their charts. What would you suggest they do?
Tracy Greig: Review the audit letter that you've received. And immediately hire an auditor to come in and review the chart notes. Look at what the letter is saying. If it's really egregious, then I would say, go to your attorney and then I mean, for me personally, I've gone to trial 3 times with doctors. And we have won the case every time when I go to trial with doctors, I immediately when I get called in, I say, who is your attorney?
And has your attorney been informed at this point? Because at that point, I want to be able to talk to that attorney and it becomes that client attorney privilege. And I also want to talk to my attorney and say, I'm being called in on this. Here's what's going on, because I'm there to win a case. I'm not there to lose a case, but I'm also there as an auditor.
Have you followed the rules and regulations? Have you done everything? Did you do this knowingly? Or did you, were you just doing it and you weren't educated by the insurance companies? And I'll give an example. We had a provider here in Oregon that called us probably about seven years ago. And insurance was.
Coming in and they asked for 57, 000 back, said they had been watching him. He had been educated, knew the insurance company well, knew the person that was being named, who said they had done the training and everything. So, when I came in and started talking to them and asking, have you called your attorney and they had not called their attorney, they had called their CPA and their CPA looked at the books and said, yes, while we can see some errors are talking about.
We had no education. We didn't have no idea we were doing anything wrong. So I called the insurance company and I had left messages and said, Can I see the log books? Can I see your training? Who came out and did the training and what the dates and the times? And I was not getting returned calls. Well, I had just been to something earlier with this insurance company and had talked to the CEO.
And he said, If you ever need anything, here's my card. Call me. I had misplaced this card, so I had called it didn't fight who I was. And I said, he told me if I ever needed him to call the insurance company gave me his personal home phone. So I emailed him and for three weeks, never got a response. So at 6 00 AM, I called him.
Because I thought I'd emailed and I called your business phone and you haven't responded. Now I have your cell phone, nor your home phone. And I called him and he said, who are you? And I said, told him who I was. I said, now that I have your attention, I want to ask for for you not to disrespect me in the future.
And I said, here's our situation. So if you're willing to sit and help and talk us through this. and provide me the call logs and all of the training paperwork that your person on the insurance company level is telling me they did. then that's the easy way out. Otherwise we can have our attorneys talking and they could not find she had actually lied her way through and had never done the training and we actually settled out of court and did not have to pay a dime back.
So those are things that providers don't know what those rules and regulations are. That's why it's really important to bring an auditor in. Who knows the back end of that business to help you. And I've been called on cases where they just write the checks. They just don't want to fight with the insurance company.
And what happens then is now you're an easy target for them because they're like, well, now they're just willing to write a check to me. So we're going to be looking at them more often. Is that the way they think? Probably not, but I've seen it time and time. And I've seen those patterns, just the way insurance companies look at patterns for providers.
Whitney Owens: I'm so glad you got that number and got through. Yeah. Wow. And you have to fight like, and therapists, we don't have time for all that. And plus we have little sweethearts and we, you know, don't always advocate for ourselves, but when we're seeing clients all day, managing a practice, we can't get on the phone and make all those calls and you made it happen, you know?
And, and I just think that speaks to, it's not all, it's the importance of course, the education and someone that knows what they're doing. Correct. Also, it's also about the time and energy to do it and to do it well.
Tracy Greig: Yes. And, you know, and I love that part as my staff all says to me, boss, I don't know what area you grew up in, but you need to see a mental health counselor yourself if you love doing that stuff.
But it's really helping the mental health practices and not just our mental health practices. We do it for all of our practices. We want to see you guys succeed because without you, patients have no access. And that is the heart and soul of our business, is really be able to help those providers continue access of care for our patients.
Whitney Owens: Definitely. Well, is there anything about an audit that we didn't touch on that you feel like it's important to mention?
Tracy Greig: No, I think we've asked I could go on for days about audits, but I think as a good rounded talk, I think that really pays close attention. And so. It's making sure you're recording your time in and time out when you see your patients and making sure that when you are doing your dictation, your chart noting that you reread if you are doing speak and dragon or go daddy or AI of any kind, just make sure your chart notes are correct.
Do say what you have intention of them saying before you sign them off. Because if you're having to open up and keep doing addendums on your chart notes, that is something else that goes into the algorithms and the insurance companies see that. There is nothing that goes past an insurance in our technical world today.
Whitney Owens: Definitely. Well, I see here in the notes, when you sent your information over that you're offering a free 30 minute consult for a wife's practice listener. Is that right?
Tracy Greig: That is correct. Yes.
Whitney Owens: Okay. So how do they go about getting that
Tracy Greig: they can either call me personally on my cell phone at 541 510 6015, or they can go to our website and the last tab of our website says contact us here and they can submit their information at that at www.
twinoaksmm. com.
Whitney Owens: Right. Making it easy. Love it. Wonderful. And Tracy, just so y'all know, Tracy will be at the Wise Practice Summit. in October. So if you're looking to meet her in person, maybe sit down and have a conversation with her about what's going on in your practice, about insurance audits, whatever.
Hopefully you're not coming to talk about audits, but if you are, she can help you. And she's got a lot of valuable information to give. So I'm excited that she'll be coming. And, and, you know, Tracy, as, as you know, having people that I can partner with to understand Faye, you know, is so important to us here at Wise Practice.
And so I would also appreciate that about you. Yes. Thank you.
Tracy Greig: Yeah. And we will be coming, Whitney, with some great promotions for people at Wise Council that they won't be able to get unless they're physically there. So we really encourage people to come to the table and introduce themselves. We're going to have some wonderful games to play and yeah, good to know.
Wonderful.
Whitney Owens: Awesome. Well, I look forward to it, meeting you in person and maybe coming over and playing some games at your table. Thank you.
