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Thread: The “Compendium of Unimplemented Office of Inspector General Recommendations”

  1. #1
    Join Date
    Apr 2007
    North Carolina

    Default The “Compendium of Unimplemented Office of Inspector General Recommendations”

    AAPC: Back to School
    Even though these are currently unimplemented, it provides insight on what the OIG/CMS are currently looking at for 2010. I found the "incident to" recommendations interesting (amongst others)...

    Recommendations: (1) CMS should seek revisions to the “incident to” rule. The rule should require that physicians who do not personally perform the services that they bill to Medicare ensure that no one except licensed physicians perform the services or nonphysicians who have the necessary training, certification, and/or licensure, pursuant to State laws, State regulations, and Medicare regulations perform the services under the direct supervision of a licensed physician. (2) CMS should require physicians who bill services to Medicare that they do not perform to identify the services on their Medicare claims using a service code modifier. The modifier would allow CMS to monitor claims to ensure that physicians are billing for services performed by nonphysicians with appropriate qualifications. (3) CMS should act to address claims for services that we detected that were billed by physicians and performed by nonphysicians that were, by definition, not “incident to” services and were for rehabilitation therapy services performed by nonphysicians who did not have the training of therapists.


  2. #2
    Join Date
    Apr 2007
    Columbia, MO


    I found this interesting as well, although it is really not entirely different from the exisitng policy it is much more clear. This should put a dot at the end of the sentence when they ask "can this be done as a nurse encounter?"

    Debra A. Mitchell, MSPH, CPC-H

  3. #3
    Join Date
    Apr 2007
    Greeley, Colorado

    Thumbs up Love it!

    Thanks Rebecca!
    Lisa Bledsoe, CPC, CPMA

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