In its 2014 Work Plan, the OIG is targeting improper payments in key areas:
- Evaluation and management services, this is mainly due to Medicare contractors who have noted an increased frequency of medical records with identical documentation across services;
- Imaging services in regard to billing and payments directly related to practice expense. The OIG will focus on the practice expense components, including the equipment utilization rate;
- Payments for outpatient drugs and administration of drugs that received Medicare payments for certain medications (e.g., chemotherapy drugs) that have been identified and determined as vulnerable to incorrect coding. The OIG will be reviewing claims with the administration of these drugs to determine whether Medicare overpaid providers because of incorrect coding or overbilling of units.
The government is continuously making changes to the federal fraud and abuse laws in compliance with the healthcare reform law. It is imperative providers understand these laws and the potential financial ramifications on the practice. To ensure your practice is complying with the regulations and guidelines, it is recommended you evaluate the practice’s compliance level and identify any risk areas for noncompliance.
Recommendations for practice compliance review include:
- Audit and monitor identified risk areas
- Develop processes and procedures for dealing with risk areas
- Document practice policies and procedures
- Designate a compliance officer
- Provide compliance education for staff members
- Develop a corrective action plan to respond to any offenses
The ACR is committed to helping rheumatology practice with coding and billing compliance. The certified coding and healthcare auditors on staff are available to assist with conducting sample audits of charts to monitor coding compliance and education. For questions or additional information, contact Melesia Tillman, CPC, CPC-I, CHA, CRHC, at [email protected] or Antanya Chung, CPC, CPC-I, CRHC, CCP, at [email protected].
