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Healthcare Practice Strategies - Summer 2015 - Office of Inspector General’s 2015 Work Plan: Three Things the Feds Are Watching

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In the 2014 fiscal year, the Department of Health and Human Services Office of Inspector General (OIG) re-covered more than $4.9 billion in improper payments and excluded 4,017 individuals and entities from participation in federal health care programs.

According to the agency’s 2015 Work Plan, these are a few of the areas the agency will be monitoring during the current fiscal year and beyond:

1. Place-of-Service Coding Errors

Medicare Part B claims for services performed in ASCs and hospital outpatient departments are being reviewed to ensure that physicians are properly coding the place of service. In the past, OIG reviews determined that some physicians were incorrectly coding for non-facility places of service.

Defense: Ensure that your system for identifying the place of service for billing purposes is accurate.

2. Utilization of Sleep-testing Procedures

Due to high utilization of certain sleep-testing procedures — especially CPT codes 95810 and 95811 — the OIG is checking for duplicative testing. The agency will be looking to see if any additional tests are being ordered when the results of an initial test are still clinically pertinent.

Defense: Make sure you are not duplicating testing when ordering or performing sleep studies.

3. Imaging Services

The OIG is monitoring Medicare Part B payments for imaging services to “determine whether they reflect the expenses incurred.” Audits will focus on practice expense components (e.g., office rent, wages and equipment) including the equipment utilization rate.

Defense: Perform some benchmarking to see whether your utilization rates for imaging equipment reflect industry practices.

The OIG Work Plan is a valuable resource for identifying compliance risk areas.  You can download a copy of the 2015 Work Plan on the OIG website in the Reports and Publications archive.


Healthcare Practice Strategies - Summer 2015

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