Coding and Compliance OIG 2008 Update

A brief summary of the MD portion of the OIG 2008 Workplan

The full text (Physicians on Pages 9-13) can be found at:http://oig.hhs.gov/08/Work_Plan_FY_2008.pdf

1. Place of service- Looking for errors, whether services billed as nonfacility for higher payment were assigned the correct POS code based on the location provided.
   
2. E&M's during the global period- Will investigate to determine if the same # of post op care visits are still acceptable today when compared to 1992 when the# of E&M's expected for certain procedures were originally established. 
   
3. Psychiatric services (MD's)- reviewing services already paid to determine if they met requirements and meet medical necessity
   
4. Services of CSW's- review claims for CSW's where services for Part A & B with overlapping dates to determine if CSW services were billed to inpatients inappropriately
   
5. Select Physician services- this statement is very general and could apply to any physician service for them to determine if services were billed appropriately.
   
6. "Incident to" services- will examine services billed "incident to" the physician to see if the staff who performed them were appropriate and qualified
   
7. Polysomnography (Sleep studies)- since payment for this service tripled from 2001 to 2004, they will investigate the rise in billable services of this type
   
8. Long distance claims and Home health and SNF services- will look at claims where the patient resides a great distance from the physician's location and are receiving home health /SNF services, but still is billed for services of their physician
   
9. Assignment of benefits- will investigate if beneficiaries are balance billed over and above the Medicare allowables (including co-pay/ded) by participating providers and assess beneficiary awareness
   
10. MRI business relationships- will investigate if business relationships between those who work together to provide these services have a higher instance of billings for these services
    
11. Interventional Pain management- this is a new and growing medical specialty, CMS will review for appropriateness of these service claims and assess the oversight of the services 
    
12. Ultrasound services- investigate areas where a high utilization of services are apparent in claims data
    
13. IDTFs- investigate areas where IDTFs are in high density geographically to determine inappropriate patterns
    
14. Chiropractic claims- investigate high frequency claims to determine if provided within coverage criteria guidelines
    
15. Physician reassignment of benefits- 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 reassignments requested on their behalf to help identify schemes for fraudulent or abusive activity