The OIG (the enforcement arm of the Medicare Program) issued their 2004 workplan in September. The workplan is an outline of various projects to be addressed by the agency during the fiscal year and once again includes several projects related to “Medicare Physicians and Other Health Professionals” as follows:
Consultations: to determine the appropriateness of billings for physician consultation services ($2 billion in 2000) and the financial impact of inaccurate billings on the Medicare program. (e.g.. billing consultation codes when documentation does not include evidence of a request for advice or opinion; need for review of the identified problem and report back to the requestor).
Coding of Evaluation and Management Services: examine whether physicians accurately coded evaluation and management ser-vices, for which Medicare paid over $17 billion in 2001. (e.g. coding Evaluation and Management visits at higher levels than the documenta-tion supports based on 1995 or 1997 guidelines).
Medicare Payments to Nonphysician Practitioners: analyze trends in nonphysician practitioners’ (including nurse practitioners, clinical nurse specialists, and physician assistants) billings, proportion of complex procedures that they perform, and assess whether they have billed for procedures not covered by their scopes of practice. OIG noted a four fold increase in nonphysician practitioner services. BWH’s compliance efforts during the 2004 fiscal year will continue to focus on these services. If you have questions relative to these or other compliance concerns, please contact Neil Walsh at 617-732-9377.