Compliance is more than just an expectation – it is a necessity. Under the Patient Protection and Affordable Care Act (PPACA) a compliance plan will eventually become mandatory as a condition of enrollment in the Medicare or Medicaid program.
Currently, whether your group has a formal compliance plan or not, the Office of Inspector General (OIG) believes that health care providers should use internal controls to “more efficiently monitor adherence to applicable statutes, regulations and program requirements.” Whether billing and collections is performed “in-house” or through a billing company, it is vital the provider(s) understand what is being billed on their behalf and whether they conform to these expectations.
On the “Forms to Download” page, information is available to assist with internal audits as a low cost solution – for coding reviews, the person auditing should not be the same person who coded the service.
External audits should be performed by someone qualified and knowledgeable in anesthesia billing idiosyncrasies.In an era of decreasing payment and increasing liability, Perfect Office Solutions, Inc. (POS) offers affordable compliance reviews tailored specifically to your practice needs. If cost is a factor in why your group hasn’t been keeping up with compliance – POS has a solution. Contact [email protected] for additional information regarding affordable off-site reviews. POS also offers full on-site reviews. A pre-estimation of costs, including travel, is provided in advance.
Currently, whether your group has a formal compliance plan or not, the Office of Inspector General (OIG) believes that health care providers should use internal controls to “more efficiently monitor adherence to applicable statutes, regulations and program requirements.” Whether billing and collections is performed “in-house” or through a billing company, it is vital the provider(s) understand what is being billed on their behalf and whether they conform to these expectations.
On the “Forms to Download” page, information is available to assist with internal audits as a low cost solution – for coding reviews, the person auditing should not be the same person who coded the service.
External audits should be performed by someone qualified and knowledgeable in anesthesia billing idiosyncrasies.In an era of decreasing payment and increasing liability, Perfect Office Solutions, Inc. (POS) offers affordable compliance reviews tailored specifically to your practice needs. If cost is a factor in why your group hasn’t been keeping up with compliance – POS has a solution. Contact [email protected] for additional information regarding affordable off-site reviews. POS also offers full on-site reviews. A pre-estimation of costs, including travel, is provided in advance.
OIG website is now updated on a monthly basis
oig.hhs.gov/reports-and-publications/workplan/
You may have noticed the following work plan items are listed as "not applicable" in 2019. That doesn't mean you shouldn't pay attention to medical direction documentation or non-covered services!
OIG WORK PLAN 2013 - 2018
Anesthesia Services —Payments for Personally Performed Services
“Physicians must report the appropriate anesthesia modifier code to denote whether the service was personally performed or medically directed (Centers for Medicare & Medicaid Services, Medicare Claims Processing Manual, Pub. No. 10004, Ch. 12, § 50). Reporting an incorrect service code modifier on the claim as if services were personally performed by an anesthesiologist when they were not will result in Medicare paying a higher amount. The service code “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, whereas, the “QK” modifier limits payment to 50 percent of the Medicare allowed amount for personally performed services claimed with the AA modifier. Payments to any service provider are precluded unless the provider has furnished the information necessary to determine the amounts due (SSA § 1833(e)). We will review Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements. We will also determine whether Medicare payments for anesthesia services reported on a claim with the AA service code modifier met Medicare requirements."
(Social Security Act, § 1833(e)). (OAS; W-00-13-35706; W-00-14-35706; W-00-15-35706; various reviews; expected issue date: FY 2018)
OIG WORK PLAN 2016 - 2018
Anesthesia services–non-covered Services
"Medicare Part B covers anesthesia services provided by a hospital for an outpatient or by a freestanding ambulatory surgical center for a patient. We will review Medicare Part B claims for anesthesia services to determine whether they were supported in accordance with Medicare requirements. Specifically, we will review anesthesia services to determine whether the beneficiary had a related Medicare service."
(Social Security Act, §1862(a)(1)(A)) (OAS; W-00-17-35753; expected issue date: FY 2018)
oig.hhs.gov/reports-and-publications/workplan/
You may have noticed the following work plan items are listed as "not applicable" in 2019. That doesn't mean you shouldn't pay attention to medical direction documentation or non-covered services!
OIG WORK PLAN 2013 - 2018
Anesthesia Services —Payments for Personally Performed Services
“Physicians must report the appropriate anesthesia modifier code to denote whether the service was personally performed or medically directed (Centers for Medicare & Medicaid Services, Medicare Claims Processing Manual, Pub. No. 10004, Ch. 12, § 50). Reporting an incorrect service code modifier on the claim as if services were personally performed by an anesthesiologist when they were not will result in Medicare paying a higher amount. The service code “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, whereas, the “QK” modifier limits payment to 50 percent of the Medicare allowed amount for personally performed services claimed with the AA modifier. Payments to any service provider are precluded unless the provider has furnished the information necessary to determine the amounts due (SSA § 1833(e)). We will review Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements. We will also determine whether Medicare payments for anesthesia services reported on a claim with the AA service code modifier met Medicare requirements."
(Social Security Act, § 1833(e)). (OAS; W-00-13-35706; W-00-14-35706; W-00-15-35706; various reviews; expected issue date: FY 2018)
OIG WORK PLAN 2016 - 2018
Anesthesia services–non-covered Services
"Medicare Part B covers anesthesia services provided by a hospital for an outpatient or by a freestanding ambulatory surgical center for a patient. We will review Medicare Part B claims for anesthesia services to determine whether they were supported in accordance with Medicare requirements. Specifically, we will review anesthesia services to determine whether the beneficiary had a related Medicare service."
(Social Security Act, §1862(a)(1)(A)) (OAS; W-00-17-35753; expected issue date: FY 2018)
Excellent Resources:
FREE COMPLIANCE TRAINING!!!!
If you missed the on-site seminars hosted by the Office of Inspector General, it is now offered as a free service - either a 3 hour 45 minute video or 16 individual training modules. Take advantage of these links!!!
http://oig.hhs.gov/newsroom/video/index.asp
http://oig.hhs.gov/newsroom/video/2011/heat_modules.asp
http://oig.hhs.gov/fraud/docs/complianceguidance/thirdparty.pdf
http://oig.hhs.gov/authorities/docs/physician.pdf
http://www.physiciansnews.com/2004/11/13/oig-on-hospital-and-physician-relations/
http://asatest.asahq.org/Newsletters/2006/05-06/pracMgmt05_06.html
FREE COMPLIANCE TRAINING!!!!
If you missed the on-site seminars hosted by the Office of Inspector General, it is now offered as a free service - either a 3 hour 45 minute video or 16 individual training modules. Take advantage of these links!!!
http://oig.hhs.gov/newsroom/video/index.asp
http://oig.hhs.gov/newsroom/video/2011/heat_modules.asp
http://oig.hhs.gov/fraud/docs/complianceguidance/thirdparty.pdf
http://oig.hhs.gov/authorities/docs/physician.pdf
http://www.physiciansnews.com/2004/11/13/oig-on-hospital-and-physician-relations/
http://asatest.asahq.org/Newsletters/2006/05-06/pracMgmt05_06.html
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