Ann & Natalie's Compliance Corner
Welcome back to Ann & Natalie's Compliance Corner! This month, we bring you guidance on updating your compliance plan in response to the Office of the Inspector General's (OIG) 2007 Work Plan. Missed last month's summary of President Bush's executive order promoting healthcare price and quality transparency? Click here.
Each year, the OIG releases a Work Plan that provides insight into its enforcement priorities for investigations into Medicare and Medicaid spending. The Work Plan addresses healthcare issues such as medical necessity and coding issues, Medicaid drug reimbursement updates and a range of other health "hot button" topics. As in the past, this year's Work Plan is a great way to get an advance look at the Feds' playbook and to update your practice's compliance plan accordingly.
This year's Work Plan includes a combination of previous items and ongoing projects as well as some new initiatives.
Some areas to consider in your practice's compliance efforts include:
As in past years, the 2007 Work Plan stresses the OIG's intent to investigate instances where it appears that a hospital is unbundling outpatient services or performing inpatient-only services in an outpatient setting. Place of service coding and attempts to exploit the system to achieve higher payment rates are still very much the subject of OIG scrutiny.
The Work Plan indicates that the OIG will be on the lookout for upcoding of diagnosis-related group payments (DRGs), and plans to "analyze inpatient hospital claims to identify high or unusual patterns for selected DRGs."
As expected, the OIG is still concerned with abuses related to services billed "incident-to physician services" in this year's Work Plan. This practice enables physicians to bill for some services their staff members perform as if the doctors had personally provided them, but only in very limited, and often unclear, circumstances. Practices must ensure that all of the "incident-to" requirements are being met if and when they bill for physician-extenders.
The Deficit Reduction Act of 2005 (DRA) also played into the 2007 Work Plan, as investigators intend to review state false claims acts and several DRA-related programs. Understand how the DRA and state false claims laws could impact your practice, and remember that if a government program overpays you, you must promptly refund the overpayment.
These are just a few areas to consider when reviewing your practice's compliance plan this year. The federal government expects all practices to be familiar with the regulations governing billing and claim submission to Medicare and Medicaid. Make sure your staff and physicians are cognizant of all areas of billing and coding in the OIG Work Plan that your practice performs.
Remember, your compliance plan should not be set in stone - modify it to respond to your evolving practice, new billing rules, and the areas highlighted by the annual OIG Work Plan.
The 2007 Work Plan is available at: www.oig.hhs.gov/publications/workplan.html.
Disclaimer: The content of Compliance Corner is for general informational purposes only and should not be interpreted as compliance guidance or advice. Consult your compliance advisor or attorney for compliance or legal advice on specific issues related to your practice or compliance program.
