Codapedia is now a division of Find-A-Code

OIG Advisory Opinion Recinded - Lessons Learned

December 21st, 2017 - Wyn Staheli
Categories:   Office of Inspector General (OIG)   Compliance  
0 Votes - Sign in to vote or comment.

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 of an audit.

Recently, the OIG rescinded advisory opinion 06-04 which concerned a nonprofit, tax-exempt, charitable corporation's proposal to provide financially needy Medicare beneficiaries with assistance with premiums and cost-sharing obligations. The original advisory was issued in 2006 and it was rescinded because:

We have made this determination based on Requestor’s failure to fully, completely, and accurately disclose all relevant and material facts to OIG.

If you are a nonprofit organization who provides benefits such as this and relied on this advisory, be sure to review the findings and make sure that your program's policies and procedures remain unaffected.

LESSONS LEARNED

1. For ALL types of providers, we want to take this opportunity to point out that the Requestor did not fully disclose information. When ANY governmental program makes a request for information, DO NOT file or throw it away and hope that nothing happens. It is best to carefully read the request and respond promptly and fully.

2. Compliance programs need to be monitored to ensure that they are still in compliance when rules and regulations change.

###

Questions, comments?

If you have questions or comments about this article please contact us.  Comments that provide additional related information may be added here by our Editors.


Latest articles:  (any category)

Q/A: What Diagnosis Codes Should I Use for TMJ Headache Massage for Coverage?
October 16th, 2018 - Wyn Staheli, Director of Research
Question: We have been receiving several DDS referrals to our massage therapists who do intra-oral work. The only problem is that the referral from the DDS lists code R51 for headaches as the only DX code. Since most plans don't cover massage therapy for headaches alone, are there any codes that can distinguish the headaches as ...
Q/A: What Codes do I use for CLIA-Waived Tests?
October 16th, 2018 - Wyn Staheli, Director of Research
Question: I am a certified DOT medical examiner and have applied to get my CLIA lab (waiver) for urinalysis, finger prick blood tests for A1c, cholesterol and glucose. I realize I cannot diagnose patients with these tests, but I am using them to make decisions in the DOT process and with ...
Pelvic Floor Dysfunction Treatment Coverage
October 16th, 2018 - Wyn Staheli, Director of Research
Pelvic floor dysfunction is often the underlying cause of conditions such as pelvic pain; urinary or bowel dysfunction; and/or sexual symptoms. Treatment generally begins with an evaluation and testing (e.g, EMG) followed by a variety of services (e.g., biofeedback, manipulation, pelvic floor electrical stimulation), depending on the findings. Coverage by payers ...
Prolonged Services Its Not Just About Time
October 5th, 2018 - BC Advantage
Time, as it applies to E/M codes, has often been viewed as an "if/then" proposition. "If" the documentation shows that a majority of the encounter was based on counseling and/or coordination of care, "then" we choose the highest level of service based on the total time of the encounter. However, a ...
HCC - Acceptable Provider Interpretation for Diagnostic Testing
October 1st, 2018 - Wyn Staheli, Director of Research
The following table is taken from the Contract-Level Risk Adjustment Data Validation Medical Record Reviewer Guidance dated 2017-09-27 (see References). It is a listing of acceptable provider interpretation of diagnostic testing. Acceptable Examples include: Cardiology and Vascular Surgeons Echocardiogram (including Doppler, Duplex, Color flow of the heart vessels) EKG (electrocardiogram) – Stress test, Cardiac ...
When to Use Modifier 25 and Modifier 57 on Physician Claims
October 1st, 2018 - BC Advantage
The biggest thing modifiers 25 and 57 have in common is that they both assert that the E/M service should be payable based on documentation within the record showing the procedure should not be bundled into the E/M. After that, the similarities end, and it is important to know the...
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 ...



About Codapedia & Find-A-Code Contact Us Terms of Use Privacy Policy Advertise with Us

Codapedia™/Find-A-Code™ - 62 E 300 North, Spanish Fork, UT 84660 - Phone 801-770-4203 (9-5 Mountain) - Fax (801) 770-4428

Copyright © 2009-2018 Find A Code, LLC - CPT® copyright American Medical Association