Health Care Practice Strategies – Summer 2013 - What the Feds Are Targeting
As you develop a solid compliance plan, do so with an eye toward these areas that the federal government has indicated are a high priority for enforcement:
- Violations of the federal Stark II law (or similar state laws), which prohibits physicians from making referrals for Medicare- or Medicaid-covered designated health services to any entity in which the physician or an immediate family member has a financial interest.
- Violations of federal and state anti-kickback laws, which prohibit giving or receiving anything of value in return for referring patients for items or services that are paid for by federally funded health care programs.
- Billing for unnecessary services.
- Upcoding, especially for E&M services.
- Duplicate billing.
- Noncompliance with the “incident to” rule, which relates to the level of supervision required for services by mid-level providers incident to a physician’s care.
- Improper certification of medical necessity for durable medical equipment.
- Illegitimate arrangements with billing services
- Resubmission of unpaid claims.
- Violations of the prohibition against reassignment of physician billing numbers
- Use of existing physician billing numbers for new doctors waiting to receive their own numbers.
- Failure to refund overpayments.
Source: OIG Work Plan
Health Care Practice Strategies – Summer 2013 Issue