Neurology & Pain Management Coding Alert

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Compliance Alert: OIG Counts $20.4 Billion in Errors in 2008

Agency combed everything from injections to consulting agreements.

The Office of the Inspector General (OIG), in its semiannual report to Congress issued on Dec. 3, 2008, reports it recovered more than $20 billion in fiscal year 2008 -- much of which reflects dollars recouped from physicians who billed improperly.

The report lists several audit and investigation highlights that allowed the OIG to recover such huge amounts of money. Among the many surprises that may impact your facility, the OIG found that 63 percent of facet joint injection claims did not meet program requirements, for a total of $96 million in Medicare overpayments to physicians.

The top errors that the OIG found in this category -- documentation errors and billing add-on codes for bilateral injections -- are unfortunately fairly common among doctors that provide these types of injections, says Randall Karpf with East Billing in East Hartford, Conn. You can be certain these are areas the OIG will be watching very closely in the future.

Multiple Place of Service Errors Found

The OIG further reports that Medicare overpaid approximately $1.5 million to physicians in two states over a two-year period due to incorrect place of service coding. The OIG found that 85 percent of the sampled services were coded as having been performed in physicians- offices, even though they were actually performed in ASCs or outpatient hospital departments.

Consultant Firm Caught

The report also lists several criminal and civil actions that the OIG took last year. For example, a healthcare consulting firm in New Jersey paid $2.8 million to resolve allegations that the consultants artificially inflated a hospitals cost-to-charge ratios. This had the effect of triggering excessive outlier payments.

Duplicate services: The report notes that a review of home health payments in five states determined that the government paid $1 million in error to Medicaid for supplies that Medicare also paid.

The government appears inclined to continue its recovery efforts. OIG has achieved significant results in the fight against fraud, waste, and abuse in HHS programs, said Inspector General Daniel R. Levinson in the OIGs Dec. 3 press release.

To read the report in its entirety, visit the OIG Web site at www.oig.hhs.gov/publications/docs/semiannual/2008/semiannual_fall2008.pdf.