Medicare Compliance & Reimbursement

Big Brother — OIG — is watching.

The HHS Office of Inspector General (OIG) has its hot list ready for 2015. The takeaway for anesthesiologists’ offices? Be ultra-cautious about using modifier AA (Anesthesia services performed personally by anesthesiologist).

Background: The OIG Work Plan details issues that the Office of Audit Services, Office of Evaluation and Inspections, Office of Investigations, and Office of Counsel to the Inspector General will address during the fiscal year. The agency published its latest document on Oct. 31, which outlines the target areas it will be reviewing in 2015.

Differentiate ‘AA’ From ‘QK’ Modifier

Claims for personally-performed anesthesia services will be closely watched next year, according to the Work Plan.

“We will also determine whether Medicare payments for anesthesiologist services reported on a claim with the ‘AA’ service code modifier met Medicare requirements,” the OIG states in the Work Plan. “Reporting an incorrect service code modifier on the claim as if services were personally performed when they were not will result in Medicare’s paying a higher amount.”

Translation: The OIG believes that Medicare might be overpaying for anesthesia services due to misuse of modifier AA. If the anesthesiologist does not personally perform the anesthesia, you should not bill as if he did, and you shouldn’t append modifier AA to the service code.

Get ahead: If your anesthesiologist personally performs a case, you must know where he is for the entire procedure and report modifier AA with the procedure code. The payer will reimburse him for the entire case.

Know Your Place of Service

If your physicians perform a considerable number of services at ASCs or hospital outpatient departments, double and triple-check your place of service (POS) coding to ensure that you didn’t erroneously lead your payer to believe that you performed the service in your office.

“Prior OIG reviews determined that physicians did not always correctly code non-facility places of service on Part B claims submitted to and paid by Medicare contractors,” the OIG says in the Work Plan.

Translation: Because CMS reimburses more money for procedures performed in your office than those performed in hospitals, you’re getting overpaid for services that you misidentify with POS 11 (Office) if the service actually took place elsewhere.

Get ahead: If you perform services in an outpatient hospital setting, you should use place of service 22 instead of 11. If the service took place in an ASC, you should instead use POS code 24.

Remember: Even if your physician performs 80 percent of his procedures in the hospital, it’s possible that some will take place in the office, so you can never assume that you know the POS when you read a chart. You should always be sure to confirm where a procedure was performed before you file the claim with the POS code.

Resource: To read the entire 2015 OIG Work Plan, visit oig.hhs.gov/reports-and-publications/archives/workplan/2015/FY15-Work-Plan.pdf.