E/M, incident-to & POS remain in OIG crosshairs

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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 reviews Medicare fraud, waste, and compliance issues identified in the OIG 2008 Work Plan that are relevant to primary care and other physician practices. It covers broad oversight areas such as E/M billing during global periods, place of service reporting, incident-to billing, polysomnography, imaging services, home health and skilled nursing facility-related physician services, and Medicare assignment rules. The piece is aimed at coders, billers, compliance staff, and physicians who want a high-level view of what the OIG was scrutinizing and why office billing policies should be reviewed.

Why This Topic Matters

The article helps practices recognize Medicare billing areas that may draw audit attention and prompts review of internal policies, documentation, and claim accuracy. It is especially useful for organizations that bill physician services across office, facility, and post-operative settings.

Article Sections

  1. E/M billed during global period

    Discusses OIG attention to evaluation and management services reported during surgical global periods and the related compliance focus for physician practices.

  2. POS errors

    Covers place of service reporting concerns for services rendered in facility settings, including outpatient and ambulatory surgery locations.

  3. Incident-to billing

    Summarizes the OIG’s planned review of incident-to services and the associated focus areas for staff qualifications, documentation, and medical necessity.

  4. Selected physician services

    Introduces the OIG’s broader review of physician services and possible concerns involving billing arrangements and service provision.

  5. Polysomnography

    Notes OIG coverage of sleep study services and the need to consider Medicare coverage criteria and medical necessity.

  6. MRI services

    Describes OIG review of relationships among physicians and billing entities involved in imaging services and their potential effect on utilization.

  7. Ultrasound services

    Summarizes OIG interest in geographic areas with high ultrasound utilization.

  8. Long-distance home health/nursing facility patients

    Covers payment review for physician services tied to home health and skilled nursing facility beneficiaries living far from the billing physician.

  9. Medicare assignment rules

    Reviews OIG scrutiny of assignment rules and beneficiary billing practices under Medicare Part B.

What You Will Learn

  • Which Medicare compliance areas were highlighted in the OIG Work Plan
  • Why physician practices should review E/M, POS, and incident-to policies
  • What broad categories of imaging, sleep, and home health-related services were under review
  • How Medicare assignment and beneficiary billing issues fit into the OIG’s oversight priorities

Who Should Read This

  • Physician office coders
  • Medical billers
  • Compliance officers
  • Primary care practices
  • Physicians

Codes Discussed

Modifiers Discussed


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