The 2016 OIG Work Plan: 3 Takeaways for Medical Practices

June 21, 2016 by Antonio Arias, MBA, CHBME

Topics: Practice Management, Medical Billing Company

Knowing that fraud, waste, and abuse are huge problems across the healthcare space, the Office of the Inspector General (OIG) publishes a workplan outlining the ways it plans to combat those issues each year. Given that the OIG is the organization charged with preventing and investigating financial mismanagement by providers, the workplan should be required reading for physicians and medical practice managers – if only so they know what concerns to watch out for in medical billing and coding.

Naturally though, few healthcare stakeholders take the time to read the workplan and use it to mitigate their risk factors. We encourage you to be one of the few; you can access the file here on the OIG website. (It’s not laborious reading, we swear! The workplan is brief and written in conversational language.)

The full workplan lists out the OIG’s Medicare and Medicaid review initiatives and intended areas of evaluation, most of which apply primarily to hospitals and nursing homes. So just in case you don’t take our advice to read it, a few of the workplan’s most important takeaways for private-practice and other medical office-bound providers are summarized below.

Incentive Payments Are on Their Radar

Following years of incentive payments for electronic health record (EHR) implementations in medical offices and hospitals, the OIG wants to make sure all payments were appropriate and warranted in line with program criteria. Their investigation won’t circle back to you unless you were mistakenly awarded payments, but don’t be surprised to receive a follow-up call if you submitted the paperwork hastily or failed to complete all requirements.

Be Careful With Prolonged Service Codes

The OIG has taken an interest in the misuse and overuse of codes 99354-99357 in both the medical office and hospital setting. The application of prolonged service codes has long been a source of strife in the world of medical billing; the add-on codes are intended by CMS for use only in instances when additional care is provided to a patient after an evaluation and management service has been performed, but they are sometimes misused for overlong chart evaluation times, late patients, or other lags. The OIG work plan considers use of prolonged service codes to be “rare and unusual,” so expect investigation if your use of codes 99354-99357 hasn’t been.

Supply & Service Orders Under Scrutiny

Under CMS guidelines, only Medicare-enrolled physicians or nonphysician practitioners are legally allowed to bill for certain services, supplies, and durable medical equipment (DME). The OIG is reviewing select orders to make sure only enrollees earned payments – making now a good time to double check that every doctor, physician assistant, and/or nurse practitioner in your office who bills for supplies and equipment has the appropriate credentials to do so.

For help ensuring your revenue cycle efforts aren’t subject to OIG scrutiny, contact NCG Medical Billing.

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