Medicare Compliance & Reimbursement

The latest round of HHS Office of Inspector General inquiries into how well hospitals comply with rules on Medicare bad debt reimbursement identify a number of compliance trouble spots — some in familiar areas hospital compliance officers should take note of.

Bad debt — i.e., Medicare coinsurance amounts that aren’t reasonably collectible — can be reimbursed under Medicare, but hospitals seeking payment have to follow the rules to the letter.

The OIG, however, has conducted a welter of audits on the issue that routinely identify compliance problems. Tallying the results of three of the latest reports, the list of watch areas includes:

• lack of sufficient collection efforts;

• bad debt claims for non-covered services;

• inadequate documentation;

• clerical and accounting errors;

• duplicate claims;

• faulty bad debt logs; and

• failing to offset recoveries on previously written-off bad debts.

Lesson Learned: Hospital compliance officers should take a close look at their bad debt policies and procedures, since the OIG is eying the issue closely.

The reports are titled “Review of Medicare Bad Debts Claimed by the Baystate Medical Center for Fiscal Year Ended September 30, 1999” (A-01-02-00515), “Review of Medicare Bad Debts at Pitt County Memorial Hospital for the Fiscal Year Ended September 30, 1999” (A-04- 02-02016) and “Medicare Inpatient And Outpatient Bad Debts Claimed By Montefiore Medical Center For Fiscal Year Ended December 31, 1999” (A-02-02-01031). A fourth report on the issue, “Review of Inpatient Medicare Crossover Bad Debts Claimed at Three Hospitals in California” (A-09-02-00092), takes the measure of whether a trio of Golden State hospitals claimed bad debts in accordance with a 1999 settlement between the Centers for Medicare and Medicaid Services and the state health department.

To see the reports, go to http://oig.hhs.gov/oas/oas/cms.html.