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 [...]