Ob-Gyn Coding Alert

The U.S. Health and Human Services Department Office of Inspector General (OIG) plans to focus on E/M services claims and, in particular, consultations as well as services and supplies reported "incident-to" physicians'services, according to the agency's work plan for 2003.

Continued interest in these areas reveals the ongoing difficulty physicians and coders experience when documenting and reporting these services. The OIG plan targets those areas of physician billing it intends to watch most closely in the next 12 months.

Among its stated goals, 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 ever harder to document upper-level E/M services thoroughly. Physicians reporting a higher-than-average number of upper-level services, whether legitimately or otherwise, may find themselves facing an audit.

With respect to incident-to services, OIG has argued, "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 physicians are reporting such services four times as often in recent years. Here again, providers must take care to document that an employee of the practice and under a physician's direct (in-office) supervision provides incident-to services and to be certain that NPP services meet scope-of-practice requirements.

Other areas of interest for 2003 include scrutiny of the correct use of the Correct Coding Initiative edits by Medicare carriers and billing for "long-distance" physician claims (that is, claims for face-to-face physician encounters when the practice setting and the beneficiary's location are separated by a significant distance).

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.