The Office of Inspector General (OIG) of the Dept of Health and Human Services released its FY2009 Workplan yesterday. The Workplan outlines the initiatives and audits that the OIG expects to undertake in the coming fiscal year. Below are some of the key initiatives that the OIG expects to undertake with regard to physicians. If you or your practice is engaged in any of these activities, now would be a great time to review whether you are complying with applicable Medicare rules. If you need assistance reviewing any of your services for compliance with Medicare rules, please contact Todd Rodriguez.
Place of Service Errors
The OIG will review physician coding of place of service on Medicare Part B claims for services performed in ambulatory surgical centers (ASC) and hospital outpatient departments. The OIG will be looking to determine whether physicians properly coded the places of service on claims for services provided in ASCs and hospital outpatient departments.
Evaluation and Management Services During Global Surgery Periods
The OIG will review industry practices related to the number of evaluation and management (E&M) services provided by physicians and reimbursed as part of the global surgery fee. It will be looking determine whether industry practices related to the number of E&M services provided during the global surgery period have changed since the global surgery fee concept was developed in 1992.
Outpatient Physical Therapy Services Provided by Independent Therapists
The OIG will review outpatient physical therapy services provided by independent therapists to determine if they are in compliance with Medicare reimbursement regulations. The review will focus on independent therapists who have a high utilization rate for outpatient physical therapy services.
“Incident To” Billing (Physicians’ Medicare Services Performed by Nonphysicians)
The OIG will review “incident to” services (i.e., services that physicians bill to Medicare but do not perform personally). The OIG will examine the qualifications of nonphysician staff that perform “incident to” services and assess whether these qualifications are consistent with professionally recognized standards of care.
Geographic Areas with a High Density of Independent Diagnostic Testing Facilities
The OIG will review services and billing patterns in geographic areas with high concentrations of independent diagnostic testing facilities (IDTF). In areas with a high density of IDTFs, the OIG will examine service profiles, provider profiles, beneficiary profiles, and billing patterns.
Patterns Related to High Utilization of Ultrasound Services
The OIG will review services and billing patterns in geographic areas with high utilization of ultrasound services paid under the Physician Fee Schedule. In areas of high utilization of ultrasound services, the OIG will examine service profiles, provider profiles, and beneficiary profiles.
Physician Reassignment of Benefits
The OIG will review the extent to which Medicare physicians reassign their benefits to other entities. The OIG will examine a national sample of Medicare physicians to determine the extent to which they reassign their benefits to other entities and the extent to which the physicians are aware of their reassignments.