12/17/2010

2011 OIG Work Plan for Physicians

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INCREASING REVENUES IN THE BUSINESS OFFICE
Presented byBA,Jennifer
Richard S. Blauvelt, MHSM Hume, CPC, CPMA, CEMC
President/CEO
PRO-DOC SOLUTIONS

2011 OIG WORKPLAN FOR PHYSICIANS

OIG WORKPLAN

• Released on October 1 of each year

• Coincides with the start of the new fiscal year for the
government

• Lists key investigative priorities.

• Multiple “parts”
-Part 1 addresses Medicare Part A and Part B services.

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2011 OIG WORKPLAN FOR PHYSICIANS

OIG WORKPLAN—PART 1

Addresses many different provider types

Provider Types

Home Health
Hospitals Nursing Facilities
Agencies

Other Providers & Medical Equipment Part B Payments for

Suppliers & Supplies Prescription Drugs

Medicare Part A and Part B Contractor Operations

2011 OIG WORKPLAN FOR PHYSICIANS

OIG WORKPLAN—PART 1

• Evaluation and Management Services

• Diagnostic Testing

• Medicare Program – General

• Medical Necessity

• Comprehensive Error Rate Testing

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2011 OIG WORKPLAN FOR PHYSICIANS

OTHER PROVIDERS AND SUPPLIES

Evaluation and Management Services

• Coding of E/M services

• Payments for E/M services

• E/M services during global surgery periods

2011 OIG WORKPLAN FOR PHYSICIANS

OTHER PROVIDERS AND SUPPLIES

Diagnostic Testing

• Appropriatness of Medicare payments for

polysomnography

• Medicare payments for sleep testing

• Excessive payments for diagnostic tests

• Medicare payments for Part B imaging services

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2011 OIG WORKPLAN FOR PHYSICIANS

OTHER PROVIDERS AND SUPPLIERS

Medicare Program – General

• Medicare providers’ compliance with assignment rules

• Payments for services ordered or referred by excluded

providers

• Medicare services billed with dates of service after

beneficiary’s date of death

• Place of service errors

2011 OIG WORKPLAN FOR PHYSICIANS

OTHER PROVIDERS AND SUPPLIERS

Medical Necessity

• Medicare payments for claims deemed not reasonable

and necessary

• Medicare billings with modifier GY

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2011 OIG WORKPLAN FOR PHYSICIANS

OTHER PROVIDERS AND SUPPLIERS

Comprehensive Error Rate Testing

• Comprehensive Error Rate Testing (CERT) Program:

FY2010 error rate oversight

• Error-prone providers: Medicare Part A and Part B

2011 OIG WORKPLAN FOR PHYSICIANS

OTHER PROVIDERS AND SUPPLIES

Providers other than physicians

Therapists Hospice
Independent Diagnostic Comprehensive Outpatient
Testing Facilities (IDTFs) Rehabilitation Facilities
(CORF)
Portable x-ray suppliers Clinical laboratories
ESRD services Clinical Social Workers
Ambulatory surgery centers Partial Hospitalization
Services

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2011 OIG WORKPLAN FOR PHYSICIANS

OTHER WORKPLAN PARTS

Don’t limit workplan reviews to just the other providers and suppliers
section
• Hospital:
Medicare Secondary Payer/Other Insurance Coverage: We will
review Medicare payments for beneficiaries who have other
insurance. Pursuant to the Social Security Act, § 1862(b),
Medicare payments for such beneficiaries are required to be
secondary to certain types of insurance coverage. We will assess
the effectiveness of procedures in preventing inappropriate
Medicare payments for beneficiaries with other insurance
coverage. For example, we will evaluate procedures for
identifying and resolving credit balance situations, which occur
when payments from Medicare and other insurers exceed the
providers’ charges or the allowed amounts. (OAS;
W‐00‐11‐35317; various reviews; expected issue date: FY 2011;
new start)

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2011 OIG WORKPLAN FOR PHYSICIANS

HOW TO USE THE WORKPLAN

• Review when issued

• Identify key investigative priorities that may affect your

practice

• Incorporate into your annual compliance audit plan

Example: General surgical practice and E/M services

during the global surgical package

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2011 OIG WORKPLAN FOR PHYSICIANS

DEMONSTRATE COMPLIANCE

• Document your efforts

• Identify issues and take corrective action

• Document

—Issue

—Findings

—Corrective actions

—Resolution

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2011 OIG WORKPLAN FOR PHYSICIANS

QUESTIONS

Thank you for attending!

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