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How to Prepare Your Practice for a Medicare Audit

Michael Caputo

For any medical practice, a Medicare audit ranks among the most stressful events to navigate. Even with solid documentation and billing processes in place, uncertainty remains. However, with the right preparation, structure, and support, your practice can move through the process confidently.

JARALL Medical Management helps practices strengthen compliance, documentation, and reporting to stay audit-ready at all times.

Why Medicare Audits Are Increasing

Medicare has ramped up auditing activity due to several converging factors:

Rising fraud and abuse prevention initiativesCMS continues to expand oversight programs

Data analytics detecting irregular billing patternsautomated systems flag outliers faster than ever

New CMS regulations and tighter reimbursement requirementscreating more compliance checkpoints

Higher scrutiny of high-risk services and specialtiespodiatry among them

Common Audit Triggers

Understanding what draws audit attention is the first step in preparation:

Repetitive high-level E/M codesbilling patterns that consistently skew toward higher complexity

Missing or incomplete documentationthe single most common audit finding

Incorrect modifier usageparticularly modifiers 25, 59, and Q-modifiers

Unusual billing volumeclaim volumes that deviate from specialty norms

Frequent denials or resubmissionspatterns that suggest systemic issues

Deviations from specialty normsbilling profiles that do not match peer benchmarks

High utilization of bundled servicesunbundling patterns that raise red flags

Step 1: Strengthen Documentation

Documentation is your primary defense in any audit. Every chart should clearly support the services billed.

Document medical necessity clearlyfor every service at every visit

Match E/M levels to complexity and timeensure coding reflects what the notes actually support

Use correct CPT and ICD-10 combinationsverify linkage before submission

Maintain detailed procedure and diagnosis notesspecificity matters

Train staff on documentation requirementsmake this an ongoing effort, not a one-time event

Step 2: Conduct Regular Internal Audits

Do not wait for Medicare to find problems. Proactive internal audits should review:

Coding accuracyare the codes submitted supported by documentation?

Modifier usageare modifiers applied correctly and consistently?

Documentation completenessdo notes contain all required elements?

Payer requirementsare claims meeting current payer-specific rules?

Claim timelinesare submissions and follow-ups happening on schedule?

Step 3: Monitor Billing and Compliance Metrics

Data visibility is essential for catching issues before they escalate. Track these metrics consistently:

Denial trendsidentify patterns by code, payer, or provider

E/M code distributioncompare against specialty benchmarks

Modifier frequencywatch for overuse or underuse

Reimbursement timelinesdelays may signal underlying problems

Procedure volume by provideridentify outliers within your own practice

Payer rule changesstay current on evolving requirements

Step 4: Update Policies and Procedures

Outdated policies create compliance gaps. Keep the following current at all times:

Compliance policiesreflecting current federal and state requirements

Coding guidesupdated for annual CPT and ICD-10 changes

Medicare Local Coverage Determinations (LCDs)region-specific rules that directly affect coverage

Staff training logsdocumented evidence that your team is educated and prepared

Step 5: Correct Coding Issues Immediately

When internal audits or denial trends reveal problems, act fast. Corrective actions may include:

Updating documentation templatesto capture required elements more consistently

Retraining staffon specific problem areas identified through audits

Adjusting workflowsto prevent the same errors from recurring

Improving provider educationensuring clinicians understand how their notes affect billing

Step 6: Create an Audit Response Plan

Do not wait until an audit notice arrives to figure out your process. A written response plan should address:

Who reviews and responds to audit requestsassign clear ownership

Who gathers documentationidentify the team responsible for pulling records

Record submission timelinesknow your deadlines and build in buffer time

Staff and provider communicationestablish how information flows during an audit

Audit deadline trackingmissed deadlines can escalate consequences

Step 7: Work With a Specialized Billing Partner

A billing partner with audit experience reduces risk through:

Accurate codingreducing the errors that trigger audits in the first place

Compliant documentation guidanceensuring charts meet payer requirements

Denial monitoringcatching patterns that could draw audit attention

Transparent reportinggiving you visibility into your billing performance

Regular chart reviewsidentifying issues proactively before payers do

Consequences of Failing an Audit

The stakes are real. Failed audits can result in:

Repayment demandsreturning funds for claims that did not meet documentation standards

Penalties or interestfinancial consequences beyond the original claim amounts

Increased future auditsone failed audit often leads to more

Pre-payment reviewclaims held for review before reimbursement, severely impacting cash flow

Potential loss of provider privilegesthe most severe consequence

Staying Audit-Ready Year-Round

A Medicare audit does not have to be intimidating. Strong documentation, proactive monitoring, and a structured response plan keep your practice compliant and confident year-round. JARALL Medical Management provides the billing oversight, compliance expertise, and reporting transparency that podiatry practices need to stay prepared.

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