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Recently, the OIG rescinded advisory opinion 06-04 which concerned a nonprofit, tax-exempt, charitable corporation's proposal to provide financially needy Medicare beneficiaries with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 The original advisory was issued in 2006 and it was rescinded because: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