Health Law News From Arnold & Porter

Health Law News From Arnold & Porter

December 11, 2012
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BLOG: New reviews related to physician services in OIG’s 2013 work plan

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From international law firm Arnold & Porter LLP comes timely views on current regulatory and legislative topics that weigh on the minds of today’s physicians and health care executives.

Anthony J. Burba

Anthony J. Burba

Each year the Office of Inspector General (OIG) for the Department of Health and Human Services releases its work plan identifying key initiatives, reviews and priorities related to its oversight of the department. There are reviews and audit activities identified for each part of Medicare, and the Part B section often includes reviews relevant to physicians. In 2013, two new reviews will be conducted by the OIG in addition to several reviews that are being carried over from 2012.

The first review pertains to Medicare Part B claims for personally performed anesthesia services. The OIG is hoping to determine whether claims for these types of services were supported by documentation sufficient to satisfy Medicare requirements. The OIG plans to pay specific attention to claims with the “AA” service code modifier, and whether those claims meet Medicare requirements.

The second new review will focus on billing for ophthalmological services. The OIG plans a review of what it considers to be questionable billing in this area. The review also will include a geographic sampling to determine whether providers exhibiting questionable billing for ophthalmologic services in 2011 were concentrated in certain geographic areas.

Providers offering anesthesia or ophthalmologic services in 2013 should be aware of the OIG’s increased attention in these areas, and take care to carefully document procedures, and ensure that all submitted claims represent properly documented care meeting Medicare requirements.

Anthony J. Burba, JD, can be reached at Arnold & Porter LLP, 555 12th St. NW, Washington, DC 20004-1206; 202-942-5013; email: Anthony.Burba@aporter.com