If your practice does lab panels, sleep studies, hospice visits and more, take heed.
The HHS Office of Inspector General has published its 2010 Work Plan, which should give us all a heads up on what the watchdog agency will be auditing and evaluating this year.
Why you should care: The 115-page document is like a map for what regulators will be looking at this year, and what potential problems they’ll be passing to MAC, RAC and private payer auditors. Don’t worry. Physician issues are clustered around page 15. However, if you code for other things in your health system besides physician services, you should have a look at the table of contents.
Here’s a summary of what the OIG wants to know about physician reimbursement:
Modifier GY: By law, Medicare excludes some medical treatments, such as many screening tests, and you might want to inform patients of this fact. Although you’re not required to issue a notification to patients for excluded procedures, doing so is a courtesy to the patient and may help the process of collecting from the patient. In these cases, modifier GY applies. Medicare denied over $820 million in modifier GY claims in fiscal year 2008, and the OIG wants to further research “patterns and trends for physicians’ and suppliers’ use of modifier GY,” the Work Plan notes.
Place-of-service errors continue to be a hot-button issue for the OIG. Reimbursement for certain procedures is higher when a physician performs them in the office than when she performs them in an ambulatory surgical center or hospital outpatient department.
POS errors sometimes occur because new billers assume that every setting the physician works in is an ‘office.’ And sometimes billing software errors cause them, Dr. Bruce Rappaport told attendees at the Coding & Reimbursement Conference his past July.
Self-audit tip: Pinpoint codes you know your physician doesn’t perform in the office, and check claims for POS errors, Rappaport recommends. For example, if your office does colonscopies in the ASC, check those claims.
Caution: Make sure you understand how to properly disclose and correct any billing problems you discover during a self-audit.
Physician visits to hospice patients: If your physician has an employment arrangement with a hospice, the Part A hospice benefit should pay for part of his services. The OIG wants to make sure physician visits to hospice patients aren’t being double billed – once to Part A and once to Part B.
For certain Medicare Part B imaging services, OIG will “determine whether Medicare payment reflects the actual expenses incurred and whether utilization rate reflects current industry practices.”
Polysomnography Payments: The OIG will study why sleep study reimbursement Medicare reimbursement rose from $62 millinon in 2001 to $215 million in 2005.
Self-Audit Tip: Check your ICD-9 coding and documentation for sleep studies, because medical necessity is a big issue here.
Improperly unbundled laboratory profiles or panels.
E-prescribe incentive payments: Interestingly, the OIG will be reviewing Medicare incentive payments made in 2010 to health care professionals for their 2009 e-prescribing activities.
The OIG will assess “whether, and, if so, the extent to which incentive payments for e-prescribing activities in 2009 were made in error.” If the OIG finds that Medicare made erroneous e-prescribing payments, it will investigate how CMS remedied the overpayments.
Because the e-prescribing incentive program is just getting rolling, the investigation is an attempt for the OIG to “identify potential vulnerabilities to assist in CMS’s oversight preparations.”
AUDIO TRAINING EVENT: OIG Work Plan Explained … for Physician Practices.
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