When was the last time you checked?

The Office of Inspector General announced Monday that a self-disclosure reported by the University of South Carolina for upcoding anesthesia services as medically directed when they should have been billed as medical supervision.  The $81,861.43 payback brings to light that every group should be checking to see that services are documented and qualify as medically directed before appending modifiers. 


Not to shortchange the pain community, the OIG Monday published a report on Noridian making improper payments to the tune of $4 Million on facet joint injections. Out of 100 claims reviewed, 51 claims did not comply with one or more of the requirements listed in the guidance.  They had three recommendations that pain physicians should be on the alert for:

  1. Recoup the improper payments noted in the review.
  2. Notify physicians to exercise reasonable diligence to identify, report and return any overpayments where the facet guidance is not been followed.  (Yes, they are putting the responsibility on the providers.)
  3. Provide specific training on the billing of facet joint injections.

Ask the following questions about your practice 

  • When was your last evaluation of medical direction? 
  • Did it include both documentation and a concurrency review? 
  • When was your last focused review of facet procedures? 
  • Did it meet all documentation requirements?
If you had a lot of unknown answers to those questions, it is time to call us! ACE is available to help with reviews. Not only can we provide the review, but we also have specific education for the providers that will help document your compliance efforts.  Give us a call, we are here to help!


© 2021, Auditing for Compliance & Education, Inc.
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