Thank you to Dr McFadden for his comments on the article which appeared in the BCMJ, Issue: Vol. 55. No. 8, pages 390–393 by Dr Graham White, past chair of the Patterns of Practice Committee (POPC). This is the second printing of this article in the BCMJ.
The POPC would like to clarify multiple errors of fact in Dr McFadden’s letter to the editor. These are:
• There is no evidence that the Cory report is recognized as the “Gold Standard of Audit Integrity.”
• The structures recommended in the Cory report were in part based on the existing structures in BC. BC structures include:
– Having medical inspectors and audit hearing panel members who are true peers of the physician being audited or who is before the panel.
– Using data analysis techniques, including software programs (i.e., case-mix adjustment software pro-gram) to analyze physician practices as part of the case-finding process.
– Providing physicians with a copy of an annual mini billing profile and a guide to interpretation.
• The Billing Integrity Program does not authorize audits. This is the function of the Audit and Inspection Committee (AIC). The AIC is a four-member committee, compos-ed of three physicians (one from each of the BCMA, the College of Physicians and Surgeons of British Columbia, and the government) and one member of the public.
• After a review of information, the AIC authorizes audits of physicians’ services and billing practices, reviews all audit reports, and makes recommendations to the Medical Services Commission as to whether recovery of funds should be pursued. The Billing Integrity Program (BIP) is tasked with carrying out the actual on-site audit.
• Even where there are billing concerns, not all physicians are audited. In 2013 the number of educational letters sent to physicians was actually equal to the number of on-site audits performed.
• The medical inspector, who is a peer physician and trained to conduct the on-site audit, reviews the final error list as well as the final audit report. The suggestion that there is no requirement for consultation with peers who actually perform the service is incorrect.
Just as with any process there is always room for improvement. That is why the POPC is currently working with BIP and the MSC on improving the audit process, communications, and oversight as well as exploring and developing educational opportunities.
—Keith J. White, MD
Chair, Patterns of Practice Committee
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