Practice Management Alert

In addition to usual focus areas, you need to know about the newest targets hitting the enforcement scene

Warning: The HHS Office of Inspector General (OIG) has put out its hit list for 2005 and is hungry to audit where Medicare or another carrier spots a red flag.
 
Make sure your practice is billing compliantly by learning about the latest enforcement areas and correcting any billing problems in your practice. And this year's target list not only boasts the usual cast of characters (E/M visits, modifier -25 use, and unbundling) but also features several newer items such as care plan oversight, Medicare-excluded physicians, physical and occupational therapy services, and cardiography and echocardiography services.
 
Check out this list of lesser-known targets and the expert action points that will help your practice through an audit-free year.

 1. Care Plan Oversight. This was a target area in 2004 and is again this year. The main problem with billing care plan oversight codes (99374-99380) is that physicians must remember to log exactly what services they perform and track the time they spend correctly, says Kristine Eckis, CPC, CMM, president of Bottom Line Medical Administrative Consultants Inc. in Lake Wales, Fla.  Consequently, providers who bill for care plan oversight without adequate documentation are opening themselves up for trouble, says Eckis, who presented a recent Coding Institute teleconference on 2005 OIG targets.
 
Action point: To ensure your documentation makes the grade, use a separate tracking sheet for each care plan oversight patient with the patient's name at the top, Eckis says. Anytime you perform any service for one of these patients - such as a phone call or review of lab results - you can quickly pull the form and record the service and time spent.
 
At the end of the month, you'll be able to neatly add up the amount of care plan oversight time your physician spent and choose the correct code. Having these sheets handy with patient names will remind you to watch "for the services you perform for these patients," Eckis says.

 2. Medicare-Excluded Physicians Cannot Order Services.  The OIG cracked down on excluded physicians in 2004 and will again in 2005. Medicare will refuse to pay for a service if an excluded provider bills for it, and will also refuse to pay if an excluded provider orders it and another physician performs the service, says Patricia Trites, MPA, CHBC, CPC, CHCC, CHCO, CEO of Healthcare Compliance Resources in Augusta, Mi.
 
This often becomes a payment problem for physicians, such as radiologists, who provide ancillary services. If an excluded physician orders an x-ray for a patient, and a radiologist then performs and bills for the service, Medicare won't pay, Trites says.
 
Action point: Whenever a patient comes in with an order from another physician, run a quick database query through the Medicare-excluded physicians list on the OIG Web site (http://oig.hhs.gov/ and click on "Exclusions Database") and the debarred contractors list on the GSA Web site (http://www.epls.gov/), Trites says. You should get in the habit of doing this regularly to make sure you don't have to pay  for services that an excluded physician ordered.

 3. Physical and Occupational Therapy. The OIG makes changes to this target area every year, Trites says. This year, the OIG will be looking to see that physical and occupational therapy services were reasonable and medically necessary, adequately documented, and certified by physician certification statements.
 
Basically, physical therapists open themselves up for fraud charges if they perform and bill for services without a clearly prescribed order for treatment, Trites says.
 
Action point: To avoid any OIG attention, a physician should always verify that the patient truly needs the physical therapy she prescribes - and clearly document both the medical necessity and the specific therapy needed, Trites says. And a therapist performing services should always make sure there's a written order from the patient's provider.

4. Cardiography and Echocardiography Services. The OIG will be reviewing Medicare payments this year to make sure providers correctly bill for the professional and technical components of these services, Eckis says. This means you should brush up on when to apply modifiers -26 (Professional component) and -TC (Technical component).
 
Action point: Remember, "you have to have a separate report to bill for the professional component," Trites says. The biggest problem physicians have is that they bill for the professional service when they didn't generate a formal report, she says. So if your physician performs an EKG in the office and does a "quick read" of the results, he can only bill for the technical component. The cardiologist or other physician who does an in-depth read and makes the formal report of the service gets to bill for the professional service.