OIG to Audit Physician Reporting of Place of Service

The OIG has released the June update to their Work Plan.  The most recent update includes evaluation of physician reporting of place of service (POS).  Specifically, the OIG plans to conduct audits to identify claims improperly reported as rendered in a physician office (POS 11) when the service was rendered in an inpatient hospital setting (POS 21) or a skilled nursing facility (POS 31).

The update comes after the OIG conducted an analysis of Medicare claims billed and paid in 2018 and 2019 which suggest a significant number of physician claims were improperly paid at the higher, non-facility, reimbursement rate when the services were rendered in a facility setting.

In most cases, the Medicare non-facility reimbursement rates are substantially higher than the facility reimbursement rates. The difference in reimbursement contingent on the POS may be 40% or more which creates a significant overpayment risk for providers.

We recommend conducting a review of your processes for assignment of POS to ensure accurate reporting and reimbursement.  We also recommend conducting auditing and monitoring of POS accuracy.  Dependent on your system reporting capabilities, it may be possible to identify POS reporting errors through data analysis.

HBE’s team of coding and compliance experts is available to assist you with external reviews of your documentation, coding and reimbursement, process reviews, and data analysis.   Additionally, we can provide customized education and training for your staff.  We are also available to provide assistance with conducting risk assessments, internal investigations and policy and procedure development.  

The OIG information regarding the POS codes can be viewed here:

To see the entirety of the OIG Work Plan update visit: 

DISCLAIMER:  This newsletter contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel.

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