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Physician Possibilities 1209 OIG Shows Its Cards In 2010 Work Plan
May 27, 2015
OIG Shows Its Cards to Physician Practices in 2010 Work Plan
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Experience the Eide Bailly Difference
December, 2009 Issue
Physician Practices Possibilities
Experience the Eide Bailly Difference
Releases Work Plan for 2010By David Manning, CPA, CMPE
OIG Shows Its Cards
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OIG Shows Its Cards; Releases Work Plan for 2010
ARTICLE OVERVIEW
Each year, the Office of Inspector General (OIG) publishes a Work Plan detailing areas it will focus on when performing audits and investigations. This article highlights several areas identified by the OIG that are of special interest to physicians.
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OIG Shows Its Cards; Releases Work Plan for 2010
Each year, the Office of Inspector General (OIG) publishes a Work Plan detailing areas it will focus on when performing audits and investigations. This annual Work Plan provides an advance look where the OIG relates their planned activities for the current work year, beginning October 1. This is an ideal opportunity for health care organizations to review their own practices to determine if they are at risk for investigation or audit by the OIG.
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OIG Shows Its Cards; Releases Work Plan for 2010
For physicians, the OIG indicated they will review Place of Service reported on billing claims. Medicare Part B payments are generally higher for services performed in a physician’s office. The OIG will review claims to determine if physicians properly coded the places of service on claims for services provided in ambulatory surgical centers and hospital outpatient departments.
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OIG Shows Its Cards; Releases Work Plan for 2010
Another area specific to physicians is the use of modifier GY on claims for services that are not covered by Medicare. When physicians provide services to Medicare beneficiaries that are statutorily excluded for payment by Medicare, providers are not required to provide patients with an Advance Beneficiary Notice, but simply attach modifier GY to the service on the claim form.
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OIG Shows Its Cards; Releases Work Plan for 2010
OIG is concerned beneficiaries may unknowingly be acquiring large medical bills which they must personally pay due to inappropriate use of modifier GY. The OIG will be reviewing claims to identify patterns and trends regarding the use of modifier GY and the providers compliance with obtaining Advance Beneficiary Notices from the patient.
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OIG Shows Its Cards; Releases Work Plan for 2010
An additional area of review significant to physicians reflects OIG concerns regarding compliance with assignment rules. Physicians participating in Medicare agree to accept the direct Medicare-allowed payment as payment in full for provided services. OIG is concerned Medicare beneficiaries are unaware of their rights regarding assignment and that they are being inappropriately billed for charges beyond the Medicare-allowed amount. The OIG will assess beneficiaries’ awareness of their rights regarding potential billing violations by providers.
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OIG Shows Its Cards; Releases Work Plan for 2010
Several other areas of interest to physicians are mentioned in the Work Plan: OIG will review physician billing for Medicare hospice beneficiaries to identify whether physicians have double-billed hospice services to Part A and Part B; OIG will assess the extent of and remedy for erroneous Medicare incentive payments made for electronic prescribing activities; and OIG will determine whether industry practices related to the number of E&M services provided during global surgical periods have changed significantly since global periods were introduced in 1992.
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OIG Shows Its Cards; Releases Work Plan for 2010
In total, OIG has identified 22 areas for review in its 2010 Work Plan that pertain to physicians. A comprehensive index introduces all of the planned activities in the Work Plan. The areas identified in the Work Plan for 2010 provide a unique opportunity to know what regulators are going to do before they do it. Don’t gamble with the OIG—take advantage of this opportunity to assess your organization’s risk for investigation and audit by reviewing the full text of the OIG Work Plan at: http://oig.hhs.gov/publications/docs/workplan/2010/Work_Plan_FY_2010.pdf.
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OIG Shows Its Cards; Releases Work Plan for 2010
• David Manning, CPA, CMPE• Senior Associate• Eide Bailly LLP• T. 701-476-8334• [email protected]
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