Your Guide to the 2012 OIG Work Plan: Does Anything on This List Worry You?
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.
Physicians: Impact of Opting Out of Medicare (New)
The OIG will be checking that physicians who opted out of Medicare are not filing claims for services, and also monitor disruption of service to Medicare patients due to opt-outs.
Evaluation and Management Services: Trends in Coding of Claims
If you provided E/M services in 2009, you received part of the $32 billion paid out as 19% of all part B payments. Did you pick a code and hope your documentation was up to the task, or did you review your documentation and choose the code that reflected what was there?
Evaluation and Management Services: Provided During Global Surgery Periods
Are physicians correctly ascertaining which services are part of the global surgery period or are they mistakenly charging for services that are wrapped into the procedure or surgery? The OIG knows.
Evaluation and Management Services: Use of Modifiers During the Global Surgery Periods (New)
Check those modifiers used during the global period. This item refers to services provided during the global period that were unrelated to the original service and thereby billable.
Evaluation and Management Services: Potentially Inappropriate Payments
This is the review we’ve all been talking about. The OIG will be inspecting electronic records to see if identical documentation appears serialized in the records.
The original work plan can be found here.
Where in the OIG work plan can I find the information about the Incident-to services?
I’ve copied it here for you:
Physicians: Incident-To Services (New)
We will review physician billing for “incident-to” services to determine whether payment for such services had a higher error rate than that for non-incident-to services. We will also assess CMS’s ability to monitor services billed as “incident-to.” Medicare Part B pays for certain services billed by physicians that are performed by nonphysicians incident to a physician office visit. A 2009 OIG review found that when Medicare allowed physicians’ billings for more than 24 hours of services in a day, half of the services were not performed by a physician. We also found that unqualified nonphysicians performed 21 percent of the services that physicians did not perform personally. Incident-to services represent a program vulnerability in that they do not appear in claims data and can be identified only by reviewing the medical record. They may also be vulnerable to overutilization and expose Medicare beneficiaries to care that does not meet professional standards of quality. Medicare’s Part B coverage of services and supplies that are performed incident to the professional services of a physician is in the Social Security Act, § 1861(s)(2)(A). Medicare requires providers to furnish such information as may be necessary to determine the amounts due to receive payment. (Social Security Act, § 1833(e).) (OEI; 00-00-00000; expected issue date: FY 2013; new start)
You make my life easy. Thanks Pat. Always helpful.
So nice to hear from you and glad you find my posts helpful!
MaryPat: Great summary of the key OIG topics. Lots of topics on the list will be making medical group managers worried! But, medical practices can use this list to review their current day to day processes and coding; identify any concerns; and take action where needed.
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