July 28th, 2016
The Office of Inspector General released its Work Plan for 2012. As in past years, the Work Plan describes the areas of interest that the OIG will investigate in the coming year. There are sections for hospitals, nursing homes, and of course, physicians.
There is a pdf file attached to this article with the Part A and Part B sections of the Work Plan. The relevant section for physicians is listed as “Other Providers and Suppliers.”
For each area, CMS lists the topic and gives brief description of what they are investigating, and why. The descriptions are succinct and the reader is often left to interpret the why. Some of the topics are new starts (issues that the OIG is beginning to work on in the coming year) and some are works in progress (projects started the previous year, not yet complete.)
It is critical for physician practices to review the topics on the OIG Work Plan each October. Compare the OIG list to services performed in the practice. Review the coding rules for each topic on the list that is done in the practice, and decide if the practice needs an internal audit. If so, add it to the practice's own Compliance Plan for the year.
Evaluation and Management services remain on the Work Plan, as both continued items and new starts. The OIG is going to analyze E/M services provided during the global period (look at your use of modifiers 24, 25 and 57), at trends in the coding of claims and at identical or cloned notes. The OIG is also reviewing—again—services provided incident to a physician service and physicians with high, cumulative payments. What should you do? Be sure that all providers are enrolled in Medicare, and bill services under the correct provider number. Review the use of modifiers 24, 25, and 57 in your practice, and compare your profile to the norms for your specialty in terms of E/M levels of service.
There are indications that the OIG is going to review the quality of care received by Medicare patients. One of the topics on he work plan about Ambulatory Surgical Centers, looking at safety and the quality of procedures.
The OIG is also looking at the “appropriateness of payments” in various areas, including physical therapy, sleep clinics and partial hospitalization programs. Lab payments and payments for End Stage Renal Disease are on the plan this year.
Do you submit claims with modifiers GA or GZ? Those claims will be reviewed this year.
Take the time to download the pdf attached to this article and review it. If your practice provides services that are on the Work Plan, do your own internal review as part of your 2012 compliance activities.
|Resources:||OIG Work Plan 2012 (pdf)|