HHS' inspector general's office has freed 16 teaching hospitals from audits under its Physicians at Teaching Hospitals initiative and will use the following guidelines to conduct future ones:
It will do PATH audits only where carriers, before Dec. 30, 1992, issued clear explanations of the rules for reimbursing for the services of teaching physicians.
Won't approach a hospital about an audit until it has obtained carrier materials showing that clear instructions were given on the need for teaching physicians to be physically present.
Won't do an audit until hospitals have the chance to show that they or their teaching physicians received conflicting guidance from carriers.
Won't do an audit on upcoding for physician services if one isn't done on the physical presence requirement. This doesn't preclude a non-PATH audit of upcoding.
Will continue to credit a hospital's undercoded claims against upcoded ones to reduce any Medicare overpayments.
Egregious cases of upcoding fraud or abuse uncovered by the inspector general in auditing of pre-August 1995 records will be "appropriate for attention and resolution."