Office of Inspector General (OIG) - Articles

OIG Investigates SCAN Health for Risk Adjustment Overpayments With Surprising Results
July 26th, 2022 - Aimee L. Wilcox, CPMA, CCS-P, CST, MA, MT
We’ve seen a number of OIG risk adjustment data validation (RADV) audits recently where the independent review contractor was simply looking for any codes the payer reported that were not supported by the documentation, in an effort to declare an overpayment was made and monies are due to be repaid. However, it was refreshing to read this RADV audit and discover that the independent review contractor actually identified HCCs the payer failed to report that, while still resulting in an overpayment, was able to reduce the overpayment by giving credit for these additional HCCs. What lessons are you learning from reading these RADV audit reports?
How Would Your Organization Defend This Auditing Accusation?
May 23rd, 2022 - Aimee L. Wilcox, CPMA, CCS-P, CST, MA, MT
The Office of Inspector General (OIG) is always working on audits in a pursuit of accurate reporting and reimbursement. A recently published OIG audit report can provide great information on how to protect providers and risk adjustment payers from serious financial losses by showing exactly what the OIG is looking for and how the payer (or provider) may have defended their coding choices. In this article, you will see how the OIG audited the HCC for major depressive disorder and what Anthem did to defend its reporting.

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OIG Report Highlights Need to Understand Guidelines
July 28th, 2020 - Wyn Staheli, Director of Research
A new OIG report once again highlights the necessity for organizations to fully understand requirements for reporting services and having proper documentation. The types of problems addressed in this report are ongoing issues for multiple types of services and specialties and for many different payers.
Office of Inspector General Says Medicare Advantage Organizations are Denying Services Inappropriately
July 21st, 2020 - Aimee Wilcox
We attended the recent virtual RISE National Conference and had the opportunity to listen to presenters share their knowledge about risk adjustment and HCC reporting and data validation. Among the presenters were representatives from the Office of Inspector General (OIG), who presented findings from encounter data from 2012-2016. They began ...
Now That is Fraud! Genetic Testing "Public alert"
April 20th, 2020 - Christine Woolstenhulme, QCC, CMCS, CPC, CMRS
Genetic testing is becoming very popular. In fact, so popular you might see it in places you would not expect such as a community event, fairs or any event happening in your community. Some labs may even offer FREE screening for genetic testing. Watch for FREE screening announcements or advertisements ...
The OIG Work Plan: What Is It and Why Should I Care?
August 9th, 2019 - Namas
The Department of Health and Human Services (HHS) founded its Office of Inspector General (OIG) in 1976 and tasked it with the responsibility to combat waste, fraud, and abuse within Medicare, Medicaid, and the other HHS programs. With approximately 1,600 employees, HHS OIG is the largest inspector general's office within ...
An Update on the DHS OIG's Effort to Combat Fraud & Abuse
May 17th, 2019 - Namas
An Update on the DHS OIG's Effort to Combat Fraud & Abuse Every year, the Department of Health and Human Services (DHS) Office of Inspector General (OIG) is required by law to release a report detailing the amounts deposited and appropriated to the Medicare Trust Fund, and the source of such ...
OIG Announces - New Review For Medicare Part B Payments for Podiatry and Ancillary Services
April 23rd, 2019 - Chris Woolstenhulme, QCC, CMCS, CPC, CMRS
Due to prior OIG work identifying inappropriate payments for podiatrists and ancillary services, the OIG announced in Feb 2019 they will begin a new review starting in 2020.  The OIG stated they will review Medicare Part B payments to determine if medical necessity is supported in accordance with Medicare requirements.   Part of the ...
Anesthesia and Pain Management
October 31st, 2018 - Chris Woolstenhulme, QCC, CMCS, CPC, CMRS
Anesthesia and Pain management is under close watch from the OIG according to a report from Anesthesia Business consultants, they stated, "The Health and Human Services Office of Inspector General (HHS OIG) reports in its most recent Semi-annual Report to Congress that in FY 2017 it brought criminal actions against 881 individuals or organizations ...
Chiropractic OIG Audit Recommendations - Lessons Learned
September 28th, 2018 - Wyn Staheli, Director of Research
The OIG recently concluded an audit on a chiropractic office located in Florida and had some significant findings. They recommended the following: Refund to the Federal Government the portion of the estimated $169,737 overpayment for claims for chiropractic services that did not comply with Medicare requirements and are within the 4-year ...
Inappropriate Use of Units Costs Practice Over $800,000
June 11th, 2018 - Wyn Staheli, Director of Research & Aimee Wilcox, CPMA, CCS-P, CMHP, CST, MA, MT
A recent OIG enforcement action emphasizes the need to understand the proper use of units. A healthcare provider in Connecticut improperly submitted multiple units for drug screening urine tests. The proper billing of units has proven to be problematic for more than just lab tests. Is your billing of drugs & biologicals, injections and timed codes appropriate?
Brooklyn Chiropractor OIG Report - Lessons Learned
April 23rd, 2018 - Wyn Staheli, ChiroCode Director of Research & Dr. Evan Gwilliam, Clinical Director PayDC Software
In August of 2017, a Brooklyn chiropractor was ordered to repay $672,805 to Medicare because the reviewer found that 100% of the claims reviewed (from 2011-2012) did not meet medical necessity requirements. The chiropractor enlisted help from two reputable experts who disputed the findings of Medicare’s Professional Reviewer (MPR). However, the OIG maintained that the findings of the original auditor were valid. Since none of us have ½ million in cash just laying around, it is essential to learn, understand, and make changes where appropriate to help audit-proof patient documentation. Read here to learn more.
Dental and Medical- Controlled Substance Awareness
January 29th, 2018 - Chris Woolstenhulme, QCC, CMCS, CPC, CMRS
As an effort to cut down on opioid abuse and related crimes, in August of 2017 the Attorney General Sessions established a new Department of Justice (DOJ) section called “Opioid Fraud and Abuse Detection Unit”. Due to the serious public health issue and drug overdose deaths, this unit was established and ...
Compliance: What is it and Why is it Important
January 22nd, 2018 - Joan S. Hartman, RHIT
Compliance. It is one of the buzz words in healthcare that is heard all the time but what is it really, and why is it so important?
$4.6 million in Claims Paid Incorrectly by CMS when Using KX Modifier
January 16th, 2018 - Chris Woolstenhulme, QCC, CMCS, CPC, CMRS
$4.6 Million was paid by CMS for claims that did not comply with Medicare requirements.  The claims were paid in 2017 and reported by the Office of Inspector General (OIG) stating, "A 2017 Office of the Inspector General (OIG) report noted that, in some cases, pharmacies incorrectly billed Medicare Part B ...
OIG Advisory Opinion Recinded - Lessons Learned
December 21st, 2017 - Wyn Staheli
In the compliance world, it is important to know when the OIG makes an advisory opinion on a subject. For example, the advisory on Time of Service or Prompt Pay Discounts helps to ensure that providers are creating policies and procedures which will meet the standards of the OIG in the case ...
Summary of OIG Reports for Chiropractic
October 23rd, 2017 - Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP
The Office of the Inspector General was created to protect the integrity of the U.S. Department of Health and Human Services. They investigate fraud, waste, and abuse in HHS programs and make recommendations to various enforcement agencies. Every few years they investigate chiropractic services. Here is a summary of the reports the ...
Medicare Improper Payment Report for Chiropractic (2016)
September 1st, 2017 - Wyn Staheli
The Medicare Improper Payment Report for 2016 has been released by the OIG. Please note that the improper payment rate does not measure fraud. Rather, it estimates the payments that did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from ...
Medicare Improper Payment Report for Behavioral Health Services (2016)
September 1st, 2017 - Wyn Staheli
The Medicare Improper Payment Report for 2016 has been released by the OIG. Please note that the improper payment rate does not measure fraud. Rather, it estimates the payments that did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from ...
Cloned E/M notes
December 29th, 2015 - Codapedia Editor
Have you ever read a physician office note and thought it was strangely familiar? Or, not just familiar but identical to another note? Well, Medicare contractors have noticed the same thing, and the Office of Inspector General has included this on their 2011 Work Plan. Medicare contractors have...
It’s a home health crackdown, but your phone’s going to ring
August 5th, 2014 - Scott Kraft
Don’t be surprised if you suddenly start to get persistent calls from home health agencies concerning patients you’ve referred for home health care. Medicare has directed its supplemental medical review contractors (SMRCs) to crack down on the face-to-face visit rules required to...
OIG adds to increased scrutiny of how patients pay for rising share of drug costs
May 27th, 2014 - Scott Kraft
Charity programs that help patients pay for the rising cost-sharing obligations of needed drugs may run afoul of anti-kickback rules when the charity’s scope is so narrow that it guides the patient toward specific drugs for treatment or providers, the HHS Office of Inspector General said last...
Cloned documentation on OIG radar screen in 2014
May 23rd, 2014 - Scott Kraft
One of the areas where the OIG has its sights set in 2014 is on physician documentation. The OIG plans to review documentation of E/M services looking for what it describes as “documentation vulnerabilities.” Put more specifically, the OIG reports that Medicare Administrative...
OIG Work Plan to look at excessive patient billing, place of service errors
February 9th, 2014 - Scott Kraft
The 2014 OIG Work Plan has finally been released and, while it doesn’t have a lot of new issues for physician practices, there are definitely some areas worth your attention to avoid future compliance hassles. If you’ve been wondering where it’s been, the OIG decided to change...

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