Self-disclosure: Who Does That?

Although most providers aim to stay under the radar of the Office of Inspector General (OIG) and private payers for fraudulent billing practices, others hide intentional wrong-doing and are fearful of being discovered. While still other providers choose to self-disclose once errors and fraudulent conduct is revealed.

If your healthcare organization finds illegal billing activity, consider self-disclosure to avoid costly and long-drawn out litigation. The OIG says, “Self-disclosure gives providers the opportunity to avoid the costs and disruptions associated with a Government-directed investigation and civil or administrative litigation.”

The Self-disclosers

According to the OIG’s “Provider Self-Disclosure Settlements,” recent self-disclosures to the OIG in the month of February included:

Feb. 8 – Highland Rivers Community Service Board, in Georgia, agreed to pay $133,067.26 for alleged violation of submitting claims for psychiatric telehealth services provided to Medicare patients at Highland Rivers locations that were not eligible for Medicare telehealth reimbursement.

Feb. 9 – CHRISTUS Health and CHRISTUS Santa Rosa Health Care Corporation, agreed to pay $148,095 for alleged physician self-referrals and kickbacks. CHRISTUS allegedly paid remuneration “above fair market value to a medical distributorship owned by a physician in exchange for the physician’s referrals of Federal healthcare beneficiaries to two hospitals owned and operated by CHRSITUS hospitals.”

Feb. 9 – Fennis Bledsoe and Atlanta Dental Clinic, Inc., in Indiana, agreed to pay $125,446 for allegedly submitting “claims to Indiana Medicaid for dental services provided by non-credentialed dentists under the names of dentists who were credentialed with Indiana Medicaid.”

Feb. 13 – Northwell Health Inc., in New York, agreed to pay $12,736,087 for allegedly submitting claims to Medicare that did not meet the requirements of Medicare Local Coverage Determination, “Veterbroplasty and Vertebral Augmentation – Percutaneous, L26439.” Documentation for those claims did not support:

1. That non-surgical medical treatment typically lasting at least six weeks had failed; or
2. The existence of pathological fracture (including osteoporotic fracture), and not simply a fracture attributable to traumatic causes.

Feb. 20 – Scotland Memorial Hospital, Inc., North Carolina, agreed to pay $252,455.56 for violation of the provider-based billing requirements for sleep diagnostic and treatment services provided at Scotland Sleep Center.

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Michelle Dick

Executive Editor at AAPC

Michelle A. Dick has been executive editor for AAPC for over 10 years. Prior to her work at AAPC, she was editor-in-chief at Eli Research and Element K Journals, and disk ad coordinator, web designer/developer, and graphic artist at White Directory Publishers, Inc. She has a Bachelor of Science in Graphic Design from the State University of New York - Buffalo State and is a member of the Flower City Professional Coders in Rochester, N.Y.

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