This year the OIG has its eye on consultation-related billing snafus, and providers who routinely charge for these should be especially clear on the correct coding guidelines. A Massachusetts doctor who thought she was performing the higher-paying consultations recently had a rude awakening from investigators.
Vacant Thacker was smacked with a false-claims suit alleging that 1,800 of the consult visits she billed to Medicare and Medicaid between 1997 and 2002 actually qualified only as new or established patient visits. Thacker agreed to settle the charges, and will be repaying the government $203,422, says U.S. Attorney General Michael Sullivan. Thacker will also be cuffed to an integrity agreement to ensure future claims adhere to Medicare billing guidelines.
Lesson learned: Billers and providers should brush up on the correct definition of a consultation and double- check before filing these claims.
The Three R's: You can bill a visit as a consultation only if the Three R's are present: Request, Render and Report. You must have documentation in the medical record of a written or verbal request for a consultation from the requesting physician, and also documentation of the specific reason for the consultation; your consulting physician must render that opinion; and then your physician must send a written report of his findings back to the requesting physician.