Medicare Compliance & Reimbursement

Why it's a good idea to keep a sharp eye on Fls.

Bad news for rehab providers that don't keep tight controls on their split-claims filing.

If a Medicare patient's stay in an inpatient rehabilitation facility overlaps the cost-reporting periods before and after Jan. 1, 2002, and the IRF splits the bill, Medicare may ask it to refund payments.

Why: When the Centers for Medicare and Medicaid Services implemented the prospective payment system for IRFs on Jan. 1, 2002, the agency told IRFs to submit a single discharge bill for an entire inpatient stay that overlapped this date, the HHS Office of Inspector General explains in a Sept. 15 audit report.

Medicare regulations prohibited IRFs from splitting bills for these patients into separate fiscal years, as MaineGeneral Medical Center did for its IRF claims during FYs 2002, 2003 and 2004, the OIG says.

The hospital split claims for 38 IRF stays and received two separate Medicare payments for each stay, according to the audit report. Medicare subsequently overpaid MaineGeneral $254,915 for FYs 2002, 2003 and 2004. MaineGeneral's fiscal intermediary also gave the hospital incorrect information that contributed to its split billing in 2003 and 2004, the OIG notes. IRF Agrees To Refund Deal MaineGeneral agreed with the OIG's recommendations to work with its FI to refund the overpayments. The facility also said it would take steps to ensure that it follows Medicare's billing guidelines in the future.

To read the report, go to http://www.oig.hhs.gov/oas/reports/region1/10500508.pdf.

Lesson Learned: Nip your billing snafus in the bud early on--because your FI might not catch the errors in time to prevent an audit.