Objectives for Addressing the Inspector Generals Work Plan
Published on Wed Dec 01, 1999
By Caral Edelberg, CPC
Consulting Editor, ED Coding Alert
President, Medical Management Resources Inc. Jacksonville, FL
The Department of Health and Human Services (DHHS) Office of Inspector Generals (OIG) Year 2000 Work Plan for the Health Care Financing Administration (HCFA) contains numerous items outlining OIG plans to further monitor and improve the overall operation of the Medicare, Medicaid and Medicare Choice programs. Knowledge of these plans will better prepare coders to participate in the compliance efforts to minimize audit risks. As coding is as much about controlling risk as it is assigning billing codes, coders may find that they are more knowledgeable about compliance issues than their physicians. Here are a few high-priority items to be aware of during the upcoming year:
Physician-Related OIG Objectives
Physicians at Teaching Hospitals will continue to be scrutinized from several levelsassurance that claims are prepared correctly to reflect services by physicians working in teaching hospitals consistent with Medicare rules. This initiative also is listed as an element of future investigation under the Medicare Contractor Operations objectives and assures that OIG will be watching for violations by teaching hospitals that issue provider numbers to non-moonlighting residents. Medicare does not recognize billing by non-moonlighting residents, so any charges for services provided by residents and not personally involving the teaching physician are illegal.
Heads up on billing for services provided by medical studentsthis issue has become increasingly problematic as more academic centers look for additional sources of revenue. For more information on coding and payment rules for teaching physicians, residents and medical students, check the following Web sites: www.aamc.org and www.hcfa.gov.
Coders tip: Be sure you understand the documentation requirements and coding policies for teaching physicians, residents and medical students by reviewing information on the Web sites listed above. When in doubt, contact your academic plans compliance officer.
Automated Encoding Systems for Billing have come to the attention of OIG as possible opportunities for upcoding. In an ideal world, coders should play a role in development and/or approval of encoding systems used for coding to assure that software in consistent with Medicare and private payer requirements. Another area of concern to OIG is billing systems in general.
Coders tip: Be sure you understand how automated coding systems determine code assignment and dont be shy about asking questions. Remember that your job is to minimize the risk to your providers, and understanding any system that is used to determine codes and charges is part of that responsibility. Ask questions, provide input and never endorse something you know is wrong and can provide supporting documentation to prove is wrong.
Reassignment of Physician Benefits is still a very active hot spot for emergency medicine billing firms as emergency department (ED) groups [...]
