Check your compliance on the areas in the 2012 Work Plan before OIG does. Every practice knows that with payer audits and recoupment requests coming in, now is the time to step up your compliance but where do you start? The HHS Office of Inspector General (OIG)'s 2012 Work Plan, released on Oct. 5 can point you in the right direction. The OIG has some big plans next year for reviewing Part B claims, and they span the whole spectrum of issues, according to the OIG. Get to know these hot buttons with this rundown. Review Incident-to Billing Requirements The OIG intends to determine whether payment for incident to services showed a higher error rate than non-incident to services. "Incident-to services represent a program vulnerability in that they do not appear in claims data and can be identified only by reviewing the medical record," the Work Plan notes. "They may also be vulnerable to overutilization and expose Medicare beneficiaries to care that does not meet professional standards of quality." Best practice: In addition, when meeting the requirements for a follow-up to an established plan of care, if the physician does not directly supervise the NPP, the incident-to rules do not apply. Direct supervision means a supervising physician must be immediately available in the office suite. The supervising physician, however, does not necessarily need to be the same physician who established the patient's care plan. Pay Attention to Assignment Rules When a physician accepts assignment with Medicare, he agrees to accept the Medicare-allowed amount from the carrier as the full charge for the service provided. In 2012, the OIG plans to review "to what extent beneficiaries are inappropriately billed in excess of amounts allowed by Medicare." Best practice: Review Your E/M Coding Practices The OIG indicates in its Work Plan that it intends to review E/M claims to identify trends between 2000 and 2009, and to determine which providers "exhibited questionable billing for E/M services in 2009." In addition, the OIG will review the number of E/M services that physicians provided during global surgery periods, and will review claims for which physicians appended a modifier so they could separately collect for E/M visits during the global period. Rule of thumb: Stay Up to Date on Hospital Observation Service Coding Rules The OIG has determined that improper use of observation services "may subject beneficiaries to high cost sharing," and intends to review claims for outpatient observation visits to assess the appropriateness of the services. Stay on top of CMS's often-changing observation coding rules. For instance, CMS recently clarified how to use subsequent observation care codes 99224-99226 in MLN Matters article MM7405, in which the agency noted that these codes should only be used by the "treating physician." CPT rules allows any physician seeing the patient in an observation setting (not a consultation) to then utilize the subsequent observation codes. Differentiate 'G' Modifiers Correctly The OIG intends to review Medicare payments for claims that included the "G" modifiers (GA, GZ, GX, GY) to indicate that a Medicare denial was expected. Often, these modifiers are used in tandem with an advance beneficiary notice (ABN). In the past, the OIG has found that Medicare inappropriately paid millions for services or supplies that should have been denied. Key: Learn more: