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How the new OIG 2014 Work Plan affects your medical office

The OIG, Office of Inspector General, oversees Medicare and Medicaid enforcement and highlights areas of focus in its enforcement efforts in a Work Plan. The 2014 Work Plan was released at the end of January and contains some items of note for medical practices.

Some items are new and others have been on the OIG Work Plan in prior years and are a continuing project.

The following items directly affect medical practices:

  1. 1. Evaluation and management services. Billing for E/M services continues to be a concern for the OIG and this is noted as an ongoing project. The OIG intends to look for “documentation vulnerabilities” in paper and electronic records. The OIG’s concern? “Medicare contractors have noted an increased frequency of medical records with identical documentation across services. Medicare requires providers to select the billing code for the service on the basis of the content of the service and to have documentation to support the level of service reported.”
  2. 2. Chiropractic services. The OIG has two new items in its Work Plan that address chiropractic services and focus on questionable billing and maintenance therapy and Medicare Part B payments. The OIG is reviewing results of prior audits, evaluations and investigations for “trends in payment, compliance and fraud vulnerabilities” and will make recommendations for addressing vulnerabilities. In particular, the OIG noted that manual manipulation of the spine is only reimbursed by Medicare if there is a neuro-musculoskeletal condition. Medicare doesn’t pay for maintenance therapy. So the OIG is seeking to identify trends “suggestive of maintenance therapy billing.”
  3. 3. Physician and supplier assignment rules. The OIG continues an item in its Work Plan focusing on claim assignment involving physicians and suppliers and the effect on Medicare and beneficiaries. Concerns include noncompliance with assignment rules and excessive billing of beneficiaries.
  4. 4. Place of service. Another continuing item is improperly indicating place of service for services rendered at ambulatory surgical centers and hospital outpatient departments.
  5. 5. Physical therapists. The OIG is reviewing outpatient physical therapy services provided by independent therapists for compliance with Medicare regulations.
  6. 6. Ophthalmologists. The OIG continues an ongoing project reviewing 2012 billing for ophthalmology services, looking for questionable billing practices and inappropriate payments.
  7. 7. Mental health. The OIG has added a new item focused on a review of Medicare’s mental health provider enrollment and credentialing requirements, CMS’s oversight in verifying mental health service providers’ qualifications, and “whether selected providers have the required Federal and State qualifications to bill Medicare for mental health services.”

The following items may be of interest to medical offices but don’t directly affect them:

  1. 1. Oversight of hospital privileging. The OIG will be looking at how hospitals review physicians applying for staff privileges, including NPDB review and credential verification. The OIG cites conditions of participation requirements that hospitals have organized medical staffs that periodically evaluate members. Because your medical office’s physicians may have or apply for hospital privileges, it’s worth noting that the OIG is concerned about the review of physician’s credentials.
  2. 2. Health information technology. The OIG has added a new item focusing on security of networked medical devices at hospitals such as dialysis machines and radiology systems integrated with EMRs and health networks. A continuing item from prior Work Plan also mentions concern for the security of PHI on portable devices and media including laptops, jump drives, backup tapes and equipment considered for disposal. While medical offices are not mentioned, the OIG’s focus on information security involving electronic records and networked systems and portable devices, is a reminder to review the information security of your network systems and portable devices.

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