HHS inspectors to review Medicare coding problems in 2014

It's a few months later than normal, but the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has finally released the list of areas its auditors will target this year.

The OIG usually releases the document in the fall. However, the agency delayed its release until now to better align with priorities that the HHS has set for the year.

Some of the items in the 2014 Work Plan will be of interest to family physicians.

First, OIG will look into reports from Medicare contractors who say they've seen an increase in providers filing medical claims for different evaluation and management (E/M) services but using identical documentation. Medicare requires providers to select the billing code for a service on the basis of the unique content of the particular service and have documentation to support the level of service reported. The agency said it plans to review multiple E/M services associated with the same providers and beneficiaries to determine the extent of documentation vulnerabilities – and potentially inappropriate payments.

The OIG will also review the extent to which physicians and suppliers participated in Medicare and accepted claim assignment during 2012. As part of that review, OIG will assess the effects of participation and claim assignments on the Medicare program, such as noncompliance with assignment rules, and on beneficiaries, such as excessive billing of beneficiaries’ share of charges.

Third, OIG will review physicians’ coding on Medicare Part B claims to make sure they provided the proper place of service codes for services performed in ambulatory surgical centers and hospital outpatient departments. Prior OIG reviews have found a problem with incorrect coding of place of service on Part B claims. Mis-coding can have a big effect on program payments because Medicare pays a physician more when a service is performed in a non-facility setting, such as a physician’s office, than it does for services performed in a hospital outpatient department or, with certain exceptions, an ambulatory surgical center.

For a full list of issues, including others that may be relevant to your particular practice, consult the complete OIG 2014 work plan online.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians