Among the new areas of focus for the Office of Inspector General (the “OIG”) is increased scrutiny for incident-to services performed by non-physician practitioners. Specifically, the OIG is planning on investigating whether the non-physician practitioners are qualified to be performing the incident-to services that are being billed by physicians. This concern and others are highlighted in the recently published 2012 OIG Work Plan. Your practice can use this Work Plan to help keep your compliance plan current. Doing so allows your practice to be prepared for any audit or investigation by the OIG.
The Work Plan contains 349 new and continuing initiatives. Others include:
- Ensuring that physicians who have opted out of Medicare are no longer submitting claims;
- Reviewing the qualifications to become a critical access hospital;
- Investigating whether physician’s services were properly coded to the appropriate place of service (i.e. provided in a hospital vs. the physician’s office); and
- Examining the safety and quality of care for patients having surgeries and procedures in ambulatory surgical centers.
The entire Work Plan can be read at: OIG 2012 Work Plan
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