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Employee Benefit Plan Alert: Fiduciaries must focus on Plan Fees

The Potential Liability of Self-Funded Health Insurance Plans

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Healthcare Regulatory 2008 Update

Coding and Documentation 2008 Update
    2008 Diagnosis Code Changes
    2008 CPT Code Changes
    2008 Modifier Changes
    Consultations
    MS-DRG and Present on Admission
    OIG Work Plan
    Increasing Revenue In Your Practice

2007 Medicare Update

2006 Medicare Update

2006 Medicare Bulletin: Nine-day hold on all Medicare payments

2005 Healthcare Update

2005 New Jersey Healthcare Bulletin

2005 Healthcare Events Update

Medicare and Medicaid (CMS) Alert

2005 Medicare Update ACAP Convention


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Healthcare Litigation

Health Claims Authorization, Processing and Payment Act

Healthcare Organizations Start to Adopt Sarbanes-Oxley Regulations

The OIG Stresses the Importance of Internal Controls for Hospitals to Reduce Risk

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Coding and Documentation 2008 Update

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Amper’s Healthcare Services Group


Office of Inspector General (OIG)
Physician Work Plan 2008
  • Place of Service (POS) Errors
    • Review physician coding of POS on claims performed in ambulatory surgical centers (ASC) & hospital outpatient departments
      • Medicare pays a physician a higher amount when a service is performed in a non-facility setting (physician’s office)
  • Evaluation & Management (E&M) Services During Global Surgery Periods
  • "Incident-to" Services
    • Review medical necessity, documentation & quality of care for "incident-to" services
  • Assignment Rules by Medicare Providers
    • Review providers that may be billing beneficiaries in excess of amounts allowed by Medicare requirements & assess beneficiary awareness of the potential violations
  • Business Relationships & the Use of MRI Under the Medicare Physician Fee Schedule
    • Review relationships among physicians, billing providers, & others who work together to provide imaging services & determine whether these relationships affect levels of utilization
  • Interventional Pain Management Procedures
    • 2005 – Medicare paid nearly $2 billion for pain management
    • Will determine the appropriateness of payments for pain management & assess the oversight of these procedures
  • Geographic Areas With a High Density of Independent Diagnostic Testing Facilities (IDTF)
    • IDTF is a facility that performs diagnostic procedures independent of a physician’s office or hospital
    • Review service profiles, provider profiles, beneficiary profiles & billing patterns
    • 2006 OIG review found numerous problems
      • Non-compliance with Medicare standards
      • Improper payments
  • High Frequency Chiropractic Treatments
    • Prior OIG work found that 40% of chiropractic services were for maintenance therapy & did not meet Medicare coverage criteria
    • $186 million in improper payments
    • Review appropriateness of Medicare payments for high frequency chiropractic claims
  • Physician Reassignment of Benefits
    • Review the extent to which Medicare physicians reassign their benefits to other entities
    • A large number of reassignments may be indicative of fraudulent or abusive activity
  • Adjustments for Graduate Medical Education (GME) Payments
    • Will review audit adjustments for direct & indirect GME that fiscal intermediaries (FI’s) make while settling Medicare cost reports
      • Will determine whether the adjustments were appropriately reflected in the revised Medicare reimbursement
  • Inpatient Prospective Payment System (IPPS) Wage Indices
    • Will review hospital & Medicare controls over the accuracy of the hospital age data for CMS to calculate wage indices for IPPS
    • Prior OIG review found hundreds of millions of dollars in misreported wage data
    • Will determine whether hospitals have complied with Medicare requirements for reporting wage data & determine the effect on the Medicare program of incorrect DRG reimbursement caused by inaccurate wage data
  • Inpatient Hospital Payments for New Technologies
    • Will determine whether hospitals have submitted claims in accordance with the criteria & were appropriately reimbursed for costs associated with the new devices & technologies
  • Long Term Care Hospital (LTCH) Payments for Interrupted Stays
    • Interrupted stay occurs when a beneficiary is discharged from an LTCH to certain kinds of facilities & then returns to the same LTCH within specified periods of time
    • Will determine if payments for interrupted stays made to LTCH’s were correct
  • LTCH Short Stay Outliers
    • Review payments for cases discharged from LTCH’s with LOS well below the average for their DRG’s, which are referred as short stay outliers (SSO)
  • Provider Bad Debts
    • Review Medicare bad debts claimed by acute care IP hospitals, LTCH’s, IP rehab facilities, IP psych facilities & SNF’s to determine whether they were reimbursable
  • Compliance with Medicare’s Transfer Policy
    • Review coding of claims submitted by hospitals for erroneously coded discharges that should have been coded as transfers
  • Payments for Diagnostic X-Rays in Hospital Emergency Departments (ED)
    • Review a sample of Medicare Part B paid claims & medical records for diagnostic x-rays performed in hospital ED’s to determine the appropriateness of payments

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