Kristina B Kahan

Kristina Kahan
Senior Managing Director

Compliance; Medical Necessity; Coding; Investigations & Self Disclosures

Kristina Kahan is a Senior Managing Director at Ankura, located in Annapolis, MD. She has over 30 years of clinical, compliance, and coding experience. Since the early 1990’s, Kristina has specialized in providing coding, compliance, investigative, clinical, operational, and industry expertise to assist payers and providers. She is a Registered Nurse and a Certified Professional Coder with a specialty in risk adjustment coding. Kristina has served clients and their counsel in a wide range of engagements, including investigations, self-disclosures, pre-IRO, IRO, and expert testimony. Prior to joining Ankura, Kristina was a director within Navigant’s disputes, forensics & legal technology (DFLT) segment, which was acquired by Ankura in 2018.

  • Experience

    Kristina assists clients and their counsel in a wide range of engagements, including investigations, self-disclosures, and expert testimony. She has conducted review of hospital and physician coding compliance, emergency department facility level development, and EMTALA assessment, risk adjustment, and HCC coding, wound care, oncology services, infusion therapy coding, and documentation, coding and billing for laboratory and genetic testing, correct documentation and billing for medications (including HCPCS coding and drug waste), charge master management, radiation oncology coding, internal cardiac defibrillators (ICD), kyphoplasty surgical procedures, one day stay reviews with a focus on InterQual or Milliman criteria and inpatient medical necessity, physician evaluation and management (E/M) coding, clinic facility coding, billing, and documentation, psychiatric service coding and documentation, durable medical equipment (DME) coding and billing, and client project management, with an emphasis on healthcare compliance and coding services.

    Kristina has served as an expert in various matters relating to coding and billing of inpatient and outpatient services, medical necessity, Medicare billing and documentation requirements, and Medicare Conditions of Participation. She has performed compliance risk assessments and participated in IRO reviews.

    Kristina’s professional experience includes:

    • Managed defense of an OIG investigation of acute care hospital short stay and observation billing practices. The review focused on medical necessity of admissions, clinical support for the decision to admit, inpatient only procedures, case management policies and procedures, and the use of InterQual guidelines versus independent medical judgement.
    • Engagement director for a complex internal compliance review of a large hospital system automatically appending modifiers to claims in order to circumvent correct coding conventions. The review included data analytics of millions of billed services, statistical sampling, coding, and repayment analysis for improperly reimbursed claims.
    • Investigation of internal cardiac defibrillator services for over 100 facilities. The reviews focused on the recent Department of Justice investigation into these devices and compliance with Medicare National Coverage Determination (NCD) requirements. The results of the review were used to repay improperly reimbursed services. Her team then worked with the facility to design and implement a pre-procedure compliance review against the NCD requirements.
    • Internal investigation of oncology physician and hospital services billed with Modifier 25 on the same date of service as infusion services.
    • Evaluation of hospital system’s provider-based clinics. The review focused on compliance with applicable Medicare regulations, signage, public perception, clinic and hospital integration and supervision, location of clinics, inappropriate sharing of clinic space, and proper coding and billing of provider-based services.
    • Investigation of Wound Care and Hyperbaric Center claims subject to MAC audits. In addition to analyzing technical requirements of Local Coverage Determination (LCD) documentation, her team analyzed the medical necessity of services, frequency of services, and correct coding of procedures.
    • Assessment of a hospital system’s Compliance Program. The results of the assessment were used to inform the board of directors regarding related compliance risk by facility and plan program redesign.
    • Due Diligence for billing, and coding compliance evaluation of claims, and operations for an emergency department professional organization. The results of our work were used to inform the company’s analysis of risk and revenue generation potential in the offer process.
    • Due Diligence for compliance, and operational evaluation of dental practices. Compliance reviews focused on billing and coding compliance with applicable regulations and medical record documentation. Specific state Medicaid risk was evaluated based on individual state requirements for reimbursement.
    • Independent Review Organization

  • News & events
    • CLE International Qui Tam Conference, 01/22/2018, “Medicare Part C: Managed Care,” San Francisco, CA, with Kirsten Do
    • American Academy of Professional Coders, 01/18/2018, “Risk Adjustment Coding: Compliance & Pitfalls,” Annapolis, MD
    • Children’s Compliance Leaders Conference, 10/03/2017, “Compliance Issues in Physician Practices: Provider Based & Incident To Services,” Milwaukee, WI
    • American Academy of Professional Coders, 07/20/2017, “Documentation, Coding, & Billing for Wound Care & HBO Services,” Annapolis, MD
    • CLE International Qui Tam Conference, 11/04/2016, “Case Study: Anatomy of a Complex FCA Case,” Los Angeles, CA, with Amy Easton, Jeffrey Dickstein
    • The Healthcare Round Table for Chief Compliance Officers, 03/31/2016, “Compliance Issues in Physician Practices: Coding & Documentation for Incident To Services,” Miami, FL
    • HCCA Clinical Practice Compliance Conference, 10/12/2014, “Living in the HER: Practical Advice for Avoiding Pitfalls and Protecting Your Practice,” Philadelphia, PA, with George Breen and Diane Lindquist