The HHS Office of the Inspector General on Wednesday provided a blueprint of its priority actions for 2004 with the release of its work plan for the next fiscal year.
"The OIG objective remains targeting of available resources on those projects that best identify vulnerabilities in the department's programs and activities and that promote the economy, efficiency and effectiveness of those programs," the plan says.
The OIG lists 12 areas of focus pertaining directly to Medicare physicians and other providers. For the second year running, consultation is at the top of the list, with a study to be issued in 2004 that will determine the appropriateness of billing for physician consultation services and the reasons for inaccurate billings, as well as their financial impact on Medicare.
Aberrant physician coding patterns of evaluation and management services also will be examined, with specific attention being paid to coding disproportionately high volumes of high-level E&M codes for greater Medicare reimbursement.
Other focus areas include the use of the modifier -25 in E&M coding, place of service errors, "long distance" physician claims, care plan oversight, billing for diagnostic tests, services and supplies incident to physician services, and ordering by physicians excluded from Medicare.
The plan also says OIG intends to publish regulations for several new safe harbor exemptions from the anti-kickback statute. OIG also will review the costs and charges reported by ambulatory surgery centers, where current rates are based on 1986 survey data, according to the Medicare Payment Advisory Commission. The information will be provided to CMS to determine whether the rates need revision.
"The OIG Work Plan is required reading for compliance officers, whose compliance programs should all be structured around those issues," says attorney Frank Sheeder of Sheeder & Welch in Dallas. "They've given you a road map of what they're going to investigate. Go get your arms around it and fix it before you get a knock on the door."
