Practice Management Alert

Keep your practice out of legal hot water by paying attention to this year's enforcement focus issues

The HHS Office of Inspector General has announced its 2004 Work Plan. There's no time to waste if you haven't already checked these billing hot spots against your compliance program:

Consultations. The OIG says it will look into "the appropriateness of billings for physician consultation services."

High-level E/M codes. The OIG plans to investigate the "disproportionately high volumes" of these codes that result in greater reimbursements.

Modifier -25. With starred procedures coming to an end, the OIG will be particularly wary of excessive modifier -25 usage.

Modifiers with NCCI edits. Be sure to use modifiers appropriately and not unbundle code pairs inappropriately.

Improper documentation. Don't bill for items or services not documented or supported by inadequate documentation.

Over-ordering of tests and procedures that are not medically necessary. This will be a high-liability risk - it's identifiable by computer audits.

Inappropriate balance billing, such as billing Medicare beneficiaries for the difference between the provider charge and the Medicare allowable.

Inadequate resolution of overpayments. Failing to refund overpayments in a timely manner can make you a target for investigation.

Incident-to billing and documentation. Make sure you know all the    incident-to requirements for billing under a physician's ID number.

Upcoding and downcoding. Two mainstays on the Work Plan that you should always keep a lookout for. View the entire Work Plan online at http://oig.hhs.gov/publications/workplan.html#1.