Copy-Paste and Fraudulent Medical Billing

Excessive documentation in the electronic health record

Medical bill
Nancy R. Cohen/Photodisc/Getty Images.

While copy-paste may be a convenient tool for busy clinicians using an electronic health record (EHR), the practice can lead to inaccurate and misleading information in the EHR. Another pitfall of using the copy-paste function in the EHR is the ease with which it can support fraudulent billing.

When paper medical records were the norm, physicians wrote progress notes about patients in order to communicate with other healthcare providers.

In the age of the EHR, a major function of electronic progress notes is to provide documentation to support the billing of insurance companies. Errors in documentation lead to incorrect billing.

For example, a physician would typically perform a complete history and physical exam on a new patient in a medical practice. The history would address current illnesses, past medical problems, surgical operations, medications, allergies, family history, and social circumstances. The physical exam would cover all major body organs. It would be appropriate for the physician to document the complete history and exam, as it was performed, and to bill the insurance company for the corresponding level of care.

Suppose that the same patient returns in a few months to discuss an isolated problem (e.g. sinus pain). Instead of performing another complete history and exam, the physician would focus on the problem by asking questions and performing an exam relevant to sinus pain.

If the physician uses copy-paste to carry forward all the information from the prior note (complete history and exam) into the current note, this would falsely imply that a higher level of service was provided.

Over-documentation occurs when a higher level of care is documented in the progress note relative to the level of care that was actually provided.

Note that not all instances of over-documentation are due to misuse of the copy-paste function. Some EHRs include templates which make it easy to auto-populate fields in the progress note. Other systems generate comprehensive documentation on the basis of clicking a single check box. If the clinician does not edit the information to reflect the actual level of service provided, then over-documentation can occur.

To take it a step further, if the physician bills the insurance company for a complete history and physical when only a focused history and exam was performed, this would be fraudulent billing. Clinicians may intentionally use the copy-paste function to over-represent the amount of services provided in an effort to boost reimbursement from the insurance company. Or they may commit billing errors simply as a byproduct of trying to improve efficiency. 

In a January 2014 report, the Office of the Inspector General (OIG) of the US Department of Health and Human Services estimated the cost of health care fraud at somewhere between $75 billion and $250 billion.

The investigation concluded that the Centers for Medicare & Medicaid Services (CMS) and its contractors were ill-prepared to recognize fraudulent medical billing associated with copy-paste and over-documentation. Among other measures, the OIG recommended that audit logs and other technical advances be used to detect copy-pasted text in EHRs.


Department of Health and Human Services Office of the Inspector General. CMS and its Contractors Have Adopted Few Program Integrity Practices to Address Vulnerabilities in EHRs. Accessed on June 30, 2014.

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