Brush up your ‘incident-to' billing: OIG is watching

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains Medicare billing topics that practices should review to reduce compliance risk, especially incident-to billing for non-physician practitioners, shared or split visits in hospital settings, and several billing areas flagged by the HHS Office of Inspector General in its 2007 Work Plan. It is relevant to physician practices, compliance staff, billing teams, and non-physician practitioners who need a broad understanding of the policy areas being monitored and the documentation and site-of-service issues involved.

Why This Topic Matters

The article helps readers understand which Medicare billing areas were under scrutiny and why practices needed to pay attention to documentation, supervision, place of service, and other compliance topics.

Article Sections

  1. Incident-to billing basics and compliance risk

    Introduces Medicare incident-to billing and the general compliance concerns associated with it. The section discusses who may be involved, the practice settings affected, and the role of documentation and supervision.

  2. Risk areas and documentation practices

    Focuses on common operational risk points in incident-to billing and how practices may organize internal documentation to identify them. It also addresses the need for billing and clinical staff awareness.

  3. Shared or split visits

    Summarizes hospital-based services provided by both a physician and a non-physician practitioner under Medicare billing rules. The section highlights participation, documentation, and consultation-related distinctions.

  4. OIG targets echo for 3rd year

    Reviews the billing areas that the OIG planned to examine in its 2007 Work Plan. It covers broader oversight topics such as imaging, evaluation and management services, and place-of-service coding.

What You Will Learn

  • The general Medicare incident-to billing framework and why it draws compliance attention
  • How practices think about supervision, documentation, and site-of-service considerations
  • The concept of shared or split visits in hospital settings
  • Which broad billing areas the OIG highlighted in its 2007 Work Plan

Who Should Read This

  • Physician practices
  • Medical billing staff
  • Compliance managers
  • Non-physician practitioners
  • Practice administrators

Modifiers Discussed


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