Medicare Compliance & Reimbursement

Here are the mistakes federal inspectors are ready to pounce on. Coding, double-billing, cost reporting, documentation, non-covered services -- when it comes to claims prep, you've got all the basics covered. But despite all of your hard work, the HHS Office of Inspector General says, other liability risks can still leave you vulnerable. New draft compliance program guidance from the OIG raises the red flag on "underappreciated" threats that have emerged in hospital compliance -- threats you'll want to make sure you address. They include:

submission of outpatient procedure coding, admissions and discharges, supplemental payment considerations and use of computerized information systems;
the "Stark" law and the anti-kickback statute;
gainsharing payments to reduce or limit services;
obligations under the Emergency Medical Treatment and Active Labor Act;
substandard-care issues;
improper relationships with beneficiaries, such as gratuities, cost-sharing waivers and free transport;
privacy-rule compliance;
claim submissions in excess of usual charges; and
how to calculate "usual charges" for discounts given to un- or underinsured patients. To read the draft guidelines, go to http://a257.g.akamaitech.net/7/257/2422/06jun20041800/edocket.access.gpo.gov/2004/pdf/0412829.pdf.