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We also noted that if a hospital has relatively different data between cost report years, we potentially would be diluting the effect of our considerable auditing efforts and introducing unnecessary variability into the calculation if we were to use multiple years of data to calculate Factor 3

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Other denials arise from incorrect or missing modifiers when multiple joints are treated on the same day, lack of justification for imaging guidance, or billing 20610 alongside evaluation and management codes without supporting distinct documentation

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