It's odd isn't it. For SBRT, we bill an IMRT plan... but don't bill for IMRT treatment. Is that "upcoding" the treatment? Of course not. We just try to put in the most accurate code.
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You will never be accused of Medicaid or Medicare fraud for underbilling the government"
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is it true that underbilling is just as bad as overbilling? Can you be accused of fraud when you make a mistake that saves the government money?' This question comes up somewhat frequently, in part because people love to promote panic. I don’t know if such fear-mongering is an attempt to sell services by saying 'you need to hire us so that you code perfectly,' or perhaps whether it’s driven by a desire to generate an exciting topic of conversation – but either way, it is wrong."
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People cannot be charged with an offense for underbilling Medicare; it only becomes a problem when the system is overcharged.
I would be very surprised if Medicare had to pay him money back after the audit because the audit revealed he was problematically underbilling (which sometimes accurately and inaccurately gets called "downcoding," but again, hard to define if 77295 is a "downcode" from 77301).
Theoretical (not really) question for the people throwing up the wall re: underbilling. If you had a proton unit that does pencil beam scanning, what is the planning code used for those protons... complex isodose, 3D, or IMRT?
And if you were treating a stage one lung with 5 times 10 Gy of protons, which treatment code do you use: protons, or SBRT? Would it depend on the planning code used?