As reported in your April 7 issue ("The other upcoding probe," p. 8), federal investigators recognize that in most cases the instances of overbilling are substantially offset by instances of underbilling. However, the law provides no netting of underbilling against overbilling in determining illegal conduct.
While wild guesses of the cost of fraud and abuse (up to $100 billion annually) are frequently made, the magnitude of undercoding is ignored in the complex Medicare reimbursement system that futilely attempts to reduce all of medical science to a small set of numerical codes. It may well be that if providers were to "right-code" all claims, the net effect would result in greater Medicare payments, not savings.
All providers should join with the government in preventing fraud and abuse by adopting billing compliance programs. However, the government should not bully a provider into accepting past practices of underbilling when the provider discovers it is rightly entitled to a greater payment for an item or service actually performed.
Scott C. Withrow
Withrow, McQuade and Olsen