NAMAS Webinar Q&A: Defending Your Audit Findings 06/04/19

Post here your questions regarding auditing ,coding, documentation, and compliance. Also, join in on the conversation- help your fellow auditors and compliance professionals in the industry.

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Wed Jun 05, 2019 10:38 am

Below are the questions received during our recent webinar, Defending Your Audit Findings, originally presented on June 4, 2019. These questions have been answered by the webinar presenter, Shannon DeConda, CPC, CPC-I, CPMA, CEMC, CEMA, CRTT.

Question 1
Where can I find the meaning of Best Practice
Answer 1
Best Practices is maintaining the highest level compliance in each aspect of billing, coding, and documentation.

Question 2
We see patients across multiple states and multiple macs with different rules, but we don't code per all the macs, is it ok to follow CMS guidelines and set rules per the company ie. exam 2 -4 and 5-7 or 2-7 Set one way to review?
Answer 2
Well, the specific question is on exam findings- keep in mind that all of the MACs that have varying opinions from 1995 documentation guidelines of 2 organ systems with affected system in detail (meaning 3-4 findings about organ system) all also say on their website that they follow this rule. They cannot go rogue and have a rule that differs from documentation guidelines such as that- or you would win on appeal every time. Difficult topic to handle in an email- I hope this helps.

Question 3
Have you seen anything that gives statistics on how well physicians do with their own coding? Many think they can with the "EPIC" systems.
Answer 3
No, not really- Frank Cohen has Compliance Risk Analyzer and within it is Audit Trakker- an audit repository. It prompts during input to ask who assigned this code and you could create your own internal stats, but I know of none nationally

Question 4
How should we handle the audit/QA if the EMR allows us to see the note was copied from another provider's note? Is this education or should we count it wrong on QA?
Answer 4
Typically QA is auditing an auditor/coder- therefore my response would be that it this would reflect on the provider not the coder/auditor. In a QA role, it is a great opportunity to address how your organization views copy/paste/clinical plagiarism- therefore you should have a policy. If it is during the audit process then again- it is certainly an educational feedback element, but as to how to count it- that would again be determined by your organizations policy. if it another providers note then that is clinical plagiarism and is not valid documentation

Question 5
We don't have a QA program - but I've been tasked with creating one.
Answer 5
Good luck, if we can be of assistance- let us know. (

Question 6
When an auditor is defending their findings, Shannon mentioned that we should use rules or guidelines published by MCR or the carrier and not from NAMAS. In our organization, one of our reliable sources are AAPC and the specialty organizations like “American Academy of Child & Adolescent Psychiatry” if we are reviewing Psychiatry. We go to these organizations because the coding guidelines are explained better than MCR or sometimes we can’t find clear direction from our MAC. Do you think we should refrain from using these organizations when defending our case?
Answer 6
Great question- I think you use them as a regarded opinion, but understand their guidance is just that of an opinion and/or interpretation. It is not official guidance.

Question 7
Shannon talked about “disclaimer”. Can I please have a copy of it.
Answer 7
For a copy of the NAMAS disclaimer, please send an email to
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