Q: I'm told, although I'm not convinced, that our payment for Keytruda is denied by Anthem when we use ICD-10-CM code Z51.11 (encounter for antineoplastic chemotherapy) first followed by the code for cancer, i.e., C34.12 (malignant neoplasm of upper lobe, left bronchus or lung). I reviewed the coding guidelines again and that is our instruction. Does anyone have experience with this issue?
In many companies, the compliance officer is the first to become aware of a potential compliance problem that could lead to civil or criminal liability. A best practice is to give the compliance officer the authority to conduct internal investigations.
When voluntary disclosure for overpayments is an option rather than an obligation, the provider may encounter diverse opinions among its decision-makers. Some may express a desire to bring the potential problem to the attention of the government and attempt to resolve the matter quickly without incurring criminal penalties, civil fines, or exclusions.
The application of attorney-client privilege is somewhat more complicated in situations where the client is a corporation. Although corporations are entitled to the same protection of confidentiality as noncorporate clients, the application of the privilege often turns on which corporate officials and employees sufficiently personify the corporation as a client.
