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College of Medicine Office of Compliance, Gainesville, Florida
COMPLIANCE TIPTHE OIG RELEASES THEIR 2007 WORK PLAN
The Work Plan is an important document as it discloses the focus areas of their efforts based on perceived vulnerabilities of the Department of Health and Human Services' programs.
The link to the full 94 page report: http://oig.hhs.gov/publications/docs/workplan/2007/Work%20Plan%202007.pdf.
THE HIGHLIGHTS FOR PHYSICIAN BILLING
Expect more scrutiny of claims for place of service errors, potential violations of reassignment rules, and use of E&M codes during the global surgery period.
Evaluation of "Incident to" Services - Testing to determine if Medicare standards are met for medical necessity, documentation, and quality of care. Place of Service Errors. Looking for services performed in ambulatory surgical centers and hospital outpatient departments and billed as clinic or non-hospital based services. Review of Evaluation and Management Services during Global Surgery Periods. Looking for: 1) for patterns of E&M payments during global periods, and 2) if industry practices have changed since the institution of global periods in 1992. E&M coding was on hiatus in last year's plan and is back. Psychiatric Services provided in an Inpatient Setting - Specifically, looking for group therapy sessions billed as individual sessions. Polysomnography tests - The rapid increase in payments for sleep studies has prompted a plan to test if such studies are billed appropriately to Medicare. Cataract and Laser Eye Surgery - This OIG work will target Medicare carriers to determine if they have systems in place to stop improper payments. Targeted Case Management - OIG focusing on Medicaid payments, searching for duplicate payments made to public agencies under other program authorities for the same service and, testing to confirm case management does not include the direct delivery of an underlying medical service. Welcome to Medicare exam payment is a new service introduced in 2005. OIG will be evaluating if this has been a wise expenditure of Medicare dollars. Wound care - OIG focusing on medical necessity and if carriers have controls in place to stop incorrect payments. Billing Service Companies - OIG will review relationships between billing companies and the physicians who use their services to determine how such relationships may affect billing. Physician Pathology Services - OIG is targeting pathology services performed in physician's office, as now there are over $1 billion in annual payments for such services. Specific interest in "pod" or "condo" labs. Cardiography and Echocardiography Services - Testing focuses on billing appropriately for the professional and the technical components of the services. (Modifier -26 for interpretation only) Medicare's assignment rules - investigation will look at whether patients are being billed more than the Medicare allowable for services and determine if patients are aware of their rights should they be overcharged. Use of imaging services in physician offices - OIG scrutinizing the patterns of growth in imaging services provided in the office setting, including by geographic regions and practice settings. PT/OT services - OIG testing to determine whether the services are medical necessity and if the services have been certified by physician. Botox treatments - OIG testing to determine if treatments are for spastic conditions not wrinkles. IVIG ( intravenous immune globulin) - Action planned in response to complaints regarding reimbursement and availability.
If you have any questions about this tip, or another compliance concern,
the Office of Compliance for the College of Medicine is here for you.
Please call (352) 265-8359 or e-mail Nina Tarnuzzer at nwt@ufl.edu.
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