OIG 2012 Work Plan: Expect more E/M, incident-to audits

Why This Topic Matters

It helps healthcare organizations understand where federal audit attention is being directed so they can review internal billing, documentation, and compliance processes.

Article Sections

1. E/M: Use of modifiers during the global period

   Covers planned OIG review activity related to evaluation and management billing during the global surgery period and associated compliance concerns.

2. Incident-to billing

   Summarizes the planned review of incident-to services and oversight of how those services are monitored under Medicare.

3. High cumulative Part B payments

   Describes a planned review of unusually high Part B payments and the broader audit interest in outlier payment patterns.

4. Physician-owned distributors (PODs) of spinal implants

   Reviews the planned investigation into physician-owned distribution arrangements and their relationship to spinal implant purchases and claims activity.

5. Part B imaging services

   Covers the planned examination of Medicare payments for imaging services, including utilization and practice expense considerations.

6. Repeat areas of interest and compliance use

   Notes additional ongoing OIG review areas and the article’s emphasis on using the Work Plan as a compliance reference.