The 2013 Work Plan for the OIG has been released and here are some of the top items that relate to medical practices. This is a great list to use for review and discussion – Is your medical practice doing this correctly?
Incident-To Services Performed by Nonphysicians
Reasons why practices are not billing these services correctly:
Lack of understanding of incident-to
Trying to avoid the 15% reduction in reimbursement for services provided by credentialed nonphysicians
Difficulty in documenting who provided the services for charge entry
Here are some highlights from the new OIG Work Plan for FY 2012. There are more items that apply to practices, as well as items for hospitals, nursing facilities, home health, and medical equipment and supplies. The link to the complete plan is at the end of the article.
Compliance With Assignment Rules
If you accept assignment with Medicare (i.e. you accept what Medicare allows as payment for a service), the OIG wants to know if you are adhering to the allowable and not collecting more than the patient’s deductible and co-insurance.
Physicians-Owned Distributors of Spinal Implants (New)
Do physician-owned distributors (PODs) of spinal implants have a conflict of interest when they sell implants to hospitals? The OIG will investigate.
Because there is a payment differential between a service provided in a hospital outpatient department or ASC and the same service provided in the physician’s office, the OIG wants to know if you provided the service where you claimed you did.
Physicians: Incident-To-Services (New)
Incident-to services are reported on the honor system – the claim does not reflect that a mid-level provider performed the service under the supervision of a physician. The OIG will dig under the claims to see if practices really understand and follow the incident-to rules.