APA Practice Organization stops problematic testing audits by Santé Analytics

Anthem has advised that psychologists can disregard any audit letter from Santé Analytics about psychological and neuropsychological testing.

The APA Practice Organization (APAPO) scored a major recent victory when Anthem ceased its relationship with its audit vendor, Santé Analytics (Santé), in light of APAPO member complaints about the Santé audit process.

Staff in the Office of Legal and Regulatory Affairs (LRA) contacted Anthem after receiving complaints and information from the Ohio and Connecticut psychological associations about audits of psychological and neuropsychological testing being conducted by Santé on behalf of Anthem of Ohio and Connecticut. Member complaints focused on the large number of files sought and requests for sizeable refunds of claims paid. 

LRA also learned that Santé misquoted guidance from APAPO to justify its extensive refund demands. In pointing to member billing and coding guidance related to documenting start and stop times for psychotherapy, the company incorrectly characterized it as APAPO guidance related to testing.

LRA developed a collaborative relationship with Anthem last fall when resolving HIPAA issues created by the new risk adjustment audits under the Affordable Care Act (ACA). Based on this positive experience, LRA approached Anthem in the spirit of cooperation to discuss our serious concerns about the Santé audits, which by contrast were traditional managed care audits focused on recordkeeping and medical necessity.

After a series of communications, Anthem informed us that they had looked into the issue and decided to discontinue their relationship with Santé. Anthem is in the process of selecting a new vendor to conduct traditional audits in the future. Anthem described a much more reasonable approach to these audits, with an emphasis on education and communication.

If you have an audit letter from Santé Analytics, Anthem has confirmed that you need not respond to it. They recommend that you simply retain it for your records. If you returned money or had money recouped as a result of a Santé audit, Anthem has agreed to review the matter and will make determinations on a case-by-case basis whether to refund repayments.

When Anthem resumes these audits, LRA will update members regarding what to expect and how to respond should you receive an audit letter.