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Office of Inspector General Gives Green Light to Hospice Provider’s Payment to Nursing Facilities

Last week, the Office of Inspector General, OIG, issued a favorable opinion to a hospice provider seeking to make supplemental payments to skilled nursing facilities. Under the proposed arrangement, the hospice provider would make a supplemental payment to the nursing facility for dual-eligible individuals electing the hospice benefit that would be in addition to and […]

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Medicare Hospital Compliance Reviews are Legal and Sound, According to OIG

The Office of Inspector General for the Department of Health and Human Services (OIG) recently defended its practices pertaining to hospital compliance reviews in a published response to a letter from the American Hospital Association (AHA), while simultaneously announcing a voluntary suspension of reviews of inpatient short stay claims after October 1, 2013.

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2015 U.S. Department of Health and Human Services Office of Inspector General Work Plan is Published

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.

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The Harder You Work, The More Dangerous it Becomes

Many years ago I attended a compliance conference, and one of the speakers was a former FBI agent who did work with the U.S.

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An Out-of-Control Medicare Audit

What happened to Eastern Carolina internal Medicine (ECIM) in Pollocksville, North Carolina is a provider’s nightmare about government oversight run amok.

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OIG Finds Improper Payments Cost Medicare Billions

On May 29, 2014, the Department of Health and Human Services Office of Inspector General (OIG) released a report, Improper Payments for Evaluation and Management Services Cost Medicare Billions in 2010.

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OIG: Room To Improve Medicare Audits

Contractors hired by Medicare to audit the payment records of healthcare providers have a good track record spotting improper billing, the Department of Health and Human Services Inspector General concluded in a recent report, but legitimate concerns exist.

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Fiscal Year 2012 HHS OIG Work Plan

The HHS Office of Inspector General (OIG) Work Plan for Fiscal Year 2012 provides brief descriptions of activities that OIG plans to initiate or continue with respect to HHS programs and operations in fiscal year 2012.

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E/M Coding Makes OIG 2011 Work Plan

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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Place-of-Service Codes Caused $13 Million in Overpayments

Double check POS 11 shouldn’t be 22 — or 24.

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.
Based on a r…

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Recovery Audit Contractors: Know These RAC Fast Facts

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.

  • Recovery audit contractors (RACs) detect and correct past improper payments so CMS and the MACs can prevent such problems in the future
  • RACs are hired as contractors by the government, and they can can collect “contingency fees,” which means that they get a percentage of the amount that they recover from providers who were paid inappropriately The maximum RAC lookback period is three years, and they cannot review claims paid prior to Oct. 1, 2007
  • Between 2005 and 2008, RACs involved in the original demonstration project recovered over $1.03 billion in Medicare improper payments, but referred only two cases of potential fraud to CMS, according to a February OIG report on the topic, which noted that “because RACs do not receive their contingency fees for cases they refer that are determined to be fraud, there may be a disincentive for RACs to refer potential cases of fraud.”
  • Unlike RACs, the OIG is a government entity. Although the OIG also performs reviews and audits and seeks improper payments, the OIG does not collect contingency fees.

For more on the RAC program, visit

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.

Be a hero. Sign up for, and join the coding community at the Facebook Fan Page.

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Cost of Freezing Conversion Factor is Over $6 Billion — Just for 2010

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

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, and join the coding community at the Facebook Fan Page.

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Compliance Red Flag: Update Your Modifier 59 and ‘Incident To’ Guidelines

Keep signature, modifier 59, and ‘Incident To’ guidelines front and center.

If you’ve been worrying that the oncologist’s illegible signature on an order is going to come back to haunt your practice in an audit, CMS has offered

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Gastro Coders: Be Aware of Medicare Screening Reqs Or Risk Payment Denial

Following 10-year-rule eliminates G0121 rejection.

If you slip up on screening colonoscopy claims’ frequency guidelines and eligibility requirements, Medicare will pay you zilch.

Use this guidance to capture every screening dollar your gastroenterologist deserves.

Home in on Eligibility Requirements for

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Use This Sample Appeal Letter As Ammo in Your Fight Against Modifier 25 Denials

Attach your procedure notes and the OIG’s report to pack extra punch.

Even if you follow all of CMS’s rules in reporting modifier 25 (Significant, separately identifiable evaluation and management service by the same physician on the same day of the

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