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Will all of the IPAs during the Sept-Oct transition period be audited by CMS?
There is no indication at this time that CMS plans to audit all of the Sept-Oct. IPAs. CMS recently posted an update to the Medicare Program Integrity Manual , which states that “contractors shall base their medical review decisions on documentation provided to support the coding and medical necessity of services recorded on the MDS for the claim period billed.” Usually, the 5-day/Initial MDS will be the only assessment necessary to provide under most medical reviews. However, we anticipate that if the claim period billed includes an optional IPA, then that IPA assessment will be included in the review. This is clarified in the Medicare Program Integrity Manual update with the statement “If an IPA has been completed, contractors shall examine the medical documentation as described in this chapter.” In short, if the claim period selected for review includes an IPA, the medical review entity is expected to review the IPA as part of the claim review; however, not every IPA completed will necessarily be reviewed.
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