General Surgery Coding Alert

The U.S. Office of Inspector General (OIG) has released its Work Plan for 2003, which targets those areas of physician billing it intends to watch most closely in the next 12 months. As in years past, the plan focuses scrutiny on E/M services claims and in particular, consultations as well as services and supplies reported "incident-to" physicians' services. Continued interest in these areas reveals the ongoing difficulty physicians and coders have when documenting and reporting such services.

Among its stated goals, the OIG intends to "identify physicians with aberrant coding patterns, specifically coding disproportionately high volumes of high-level evaluation and management codes that result in greater Medicare reimbursement." To protect themselves, physicians must work even harder to document upper-level E/M services thoroughly. Physicians reporting a greater-than-average number of high-level services, legitimately or otherwise, may find themselves facing an audit.

With respect to incident-to services, the OIG argues, "Because little information is available on the types of services being billed, questions persist about the quality and appropriateness of these billings." Similarly, the agency will continue to scrutinize all services billed for nonphysician practitioners (NPPs), noting that reporting of such services has increased fourfold in recent years. Providers must take care to document that incident-to services are provided by an employee of the practice under a physician's direct supervision and that NPP services meet state scope-of-practice requirements.

Other areas of interest for 2003 include appropriate application of national Correct Coding Initiative edits and billing for "long-distance" physician claims, i.e., claims for face-to-face physician encounters when a significant distance separates the practice setting and the beneficiary's location. Look to future editions of General Surgery Coding Alert for in-depth coverage of coding and documentation for all services targeted by the OIG.

Note: The full text of the OIG's Work Plan is available on the U.S. Department of Health and Human Services' Web site: http://oig.hhs.gov/publications/workplan.html.