Check the OIG work plan for insights on areas to shore up for 2001
Feds are planning more than 100 initiatives next year
Practices looking to avoid the long arm of fraud and abuse laws in the coming year should be paying particular attention to the 2001 work plan just released from the Office of Inspector General (OIG).
The plan provides a road map of the areas that OIG investigators will pay particular attention to over the next year, and contains more than 100 initiatives by federal investigators. Practice managers will want to study the plan for areas that might relate to their organizations, then identify policies and procedures that may need shoring up. You may even consider launching internal audits in specific areas to test for compliance problems, and educating staff and physicians about regulatory rules, advise experts.
Hot spots in the OIG’s work plan include:
• "Incident to" services. The OIG plans to look at the conditions doctors use to bill for care given "incident to" their professional services. The OIG is particularly interested in the quality and appropriateness of these claims, and the types of "incident to" services being billed.
• Advanced beneficiary notices. ABNs are documents on which patients attest that they know or believe Medicare won’t pay for a treatment before they receive the service. There isn’t a standard protocol for how physicians hand out these notices to Medicare beneficiaries, particularly for noncovered laboratory services.
• Critical care coding. The OIG wants to see if physicians are billing appropriately for common critical care codes when a patient is critically ill and requires constant doctor supervision.
• Home health. The OIG plans to examine the extent of physicians’ involvement in approving and monitoring home care for Medicare patients. Investigators will look at the extent of physicians’ medical relationships with their home health patients, and how much they rely on the home health agency to determine what care a patient receives, all in light of the new home health prospective payment system.
• Nonphysician services to seniors. Given the expanded role nurse specialists, nurse practitioners, and physician assistants have taken on in many heath care settings, the OIG wants to see if these nonphysician providers are practicing within legally set limits, and what effect their care has had on patient care and costs.
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