As you may be aware, the 2015 U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) Work Plan was released on Oct. 31, 2014. This should be considered mandatory reading for all healthcare providers looking to avoid fraud charges.
Make sure your postop office visit documentation measures up.
The OIG has once again set its sights on several new targets to go with the upcoming new year, and this time the feds will be double- and triple-checking your E/M documentation.
On Oct. 1, the OIG published its 2011 Work Plan, which outlines the areas that the Office of Audit Services, Office of Evaluations and Inspections, Office of Investigations, Office of Counsel to the Inspector General, Office of Management and Policy, and Immediate Office of the Inspector General will address during the 2011 fiscal year. When the OIG targets an issue in its Work Plan, you can expect the agency to carefully review and audit sample claims of those services.
The Work Plan “describes the specific audits and evaluations that we have underway or plan to initiate in the year ahead considering our discretionary and statutorily mandated resources,” the document indicates.
On the agenda for next year, the OIG has indicated that its investigators will “review the extent of potentially inappropriate payments for E/M services and the consistency of E/M medical review determinations.” The OIG also plans to hone in on whether payments for E/M services performed during the global periods of other procedures were appropriate.
In addition, the OIG will scrutinize Medicare payments for Part B imaging services, outpatient physical therapy services, sleep testing, diagnostic tests, and claims with modifier GY on them (Item or service statutorily excluded, does not meet the definition of any Medicare benefit or, for non-Medicare insurers, it is not a contract benefit).
The OIG also intends to “review Medicare payments for observation services provided during outpatient visits in hospitals” to assess whether hospitals’ use of observation services affects Medicare beneficiaries’ care.
Keep your compliance plan up to date with tips from Part B Insider,…
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Entering your place-of-service (POS) number on your claim form may seem routine, but a recent OIG audit found that practices are not giving POS numbers the care they deserve.
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Practice size does not matter when dealing with compliance — even solo practitioners have to stay on the straight and narrow.
Even small dermatology practices have to stay compliant with government regulations — and although this sounds like a simple fact, it’s one that many Part B providers may overlook.
Ensuring physician practice compliance can be a complex path, and many practices think of it is something that large hospitals should focus on — after all, those are the entities that get all of the media exposure when they violate compliance rules. But every practice is responsible for compliance, no matter how big or small.
Doctors Take Note
In some cases, small practices think compliance rules don’t affect them — but also don’t realize they’re at risk of being noncompliant.
Example: “I met with a solo practitioner a few years ago who hired me as a consultant,” says Laura E. Hill, CPC, CPC-I, an Arizona- based compliance consultant.
“It was my sad duty to let him know that his office manager,who submitted all of his claims, was upcoding all of his office visits as she entered them into the computer so that she could pay his quarterly malpractice-insurance premiums,” Hill says. “She had been working for him for 10 years and was a loyal and trustworthy employee.”
The fault was the physician’s, because he never took the time to review the monthly reports that the office manager gave to him, Hill says. He also never looked closely at his deposits into his corporate checking account, where there was an obvious trend toward increased deposits every third month.
Pay attention to your advisors: In the example above, the physician’s accountant had pointed the problem out to him, “but he accepted his office manager’s explanation that insurance…
RACs are just another tool in the government’s arsenal to collect improper payments.
You’ve got so many compliance acronyms flying at you every day that you may not be able to differentiate your RAC from the OIG. Know these quick facts about RACs to stay better informed.
For more on the RAC program, visit www.cms.gov/rac.
@ Part B Insider. Editor: Torrey Kim, CPC
Sign up for the upcoming live Webinar, You Can Use the Appeals Process Like a Pro, or order the CD/transcripts.
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Plus: The OIG recovered over $1.5 billion in fiscal year 2009, and is on the lookout to collect more.
With less than two weeks to go before Medicare payments once again threaten to decrease by 21 percent, a new report sheds light on the financial outcome of Congressional actions.
Although the 2010 Physician Fee Schedule originally included a conversion factor that would have been 21 percent lower than the 2009 level, practices haven’t felt that cut yet this year,because legislators have voted several times to freeze payments, which now use the conversion factor of $36.0791. That freeze will expire on May 31, after which your Medicare payments will drop considerably unless Congress steps in once more.
However, one government entity’s calculations show that the freeze is costly. According to a May 7 Congressional Budget Office report, freezing payments at the current levels for the rest of 2010 would cost the government… … $6.5 billion. The AMA has turned up the heat on Congress to replace the current payment method, releasing a print ad aimed at Congress to demonstrate that “more delays of permanent reform now increase the cost for taxpayers,” and that the association “calls on Congress to fix the flawed Medicare physician payment formula now.”
Congress has not yet introduced a bill to extend the payment freeze past May 31. Keep an eye on the Insider for more information as this story develops.
To read the Congressional Budget Office’s calculation sheet,visit www.cbo.gov/budget/factsheets/2010b/SGR-menu.pdf.
@ Part B Insider. Editor: Torrey Kim, CPC
Sign up for the upcoming on-demand Webinar, 5 Steps to Optimize Your Office’s Coding & Billing Practices, or order the CD/transcripts.
Be a hero. Sign up for Supercoder.com, and join the coding community at the Supercoder.com Facebook Fan Page.
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answers…
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Use this guidance to capture every screening dollar your gastroenterologist deserves.
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Don’t sweat reporting 38220-59 if you meet these Medicare-approved conditions.
If your oncologist takes both a bone marrow biopsy and a bone marrow aspiration, whether you’ll see Medicare reimbursement depends on the two guidelines below. But watch out: With OIG scrutiny and a HCPCS twist, these guidelines will put your coding savvy to the test.
Append 59 […]
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