Part B Insider (Multispecialty) Coding Alert

Physician documentation, 'incident-to' are common pitfalls

The HHS Office of Inspector General's nationwide review of outpatient cardiac rehab claims will continue to hold you to the letter of the law when it comes to "incident-to" and physician documentation services.
 
In its recent audit report, "Review of the Outpatient Cardiac Rehabilitation Services - HealthSouth Sea Pines Rehabilitation Hospital - Melbourne, FL," (A-04-03-01004) the OIG sounds a familiar complaint that it could not identify the physician professional services to which the cardiac rehabilitation services were provided incident-to. The audit also blames Sea Pines for billing multiple units of service for single rehab visits.
 
But even tackling some of the more complex outpatient cardiac rehab compliance issues won't keep OIG off your back if documentation problems still linger. That was the case in two other reports, "Review of Outpatient Cardiac Rehabilitation Services At The Cooley Dickinson Hospital - Northampton, MA," (A-01-03-00516) and "Review of Outpatient Cardiac Rehabilitation Services At The Berkshire Medical Center" (A-01-03-00514). In those audits, both hospitals were in compliance for incident-to - an area where the OIG virtually always finds problems - but were still scolded for not fully documenting patients' eligibility or that a physician was personally seeing a patient periodically throughout the rehab program, per Medicare requirements.
 
To see the reports, go online to http://oig.hhs.gov/oas/oas/cms.html.