OIG Plans to Crack Down on Improper POS Coding

The Department of Health and Human Services’ Office of Inspector General will be closely watching claims with place of service (POS) indicators 22 (outpatient hospital) and 24 (Ambulatory surgical center), according to OIG’s 2008 Work Plan.
The reason for the greater scrutiny is the slightly higher payments that physicians receive when they claim services/procedures in a facility setting, such as a hospital outpatient or ASC, rather than in a nonfacility setting, such as the physician’s office. "We will determine whether physicians properly coded the places of service on claims for services provided in ASCs and hospital outpatient departments," according to the Work Plan.
In other words: CMS pays physicians more for services and procedures in facility settings, and the OIG wants to be sure that physicians aren’t taking advantage of this to pad their reimbursement improperly.
What to do: If you’re handling the facility-side coding, chances are the OIG’s investigation probably won’t affect you. Just be sure that you’re always assigning the correct POS code on each claim.
If you’re coding for a physician, the same advice applies: Report POS codes accurately and consistently. Any attempt to "game the system" and gain undeserved reimbursement by falsifying POS codes will likely land you in hot water.
Additionally: The OIG "will review the appropriateness of the methodology for setting the ASC payment rates under the revised ASC payment system," the Work Plan says. The OIG likewise will review the methodology used to calculate the new ASC payment rates, according to the American Association for Ambulatory Surgery Centers (AAASC).
To view the OIG’s 2008 Work Plan, go to http://oig.hhs.gov/publications/docs/workplan/2008/Work_Plan_FY_2008.pdf.

- Published on 2008-01-15