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OIG’S VOLUNTARY COMPLIANCE TO MEDICAL BILLING COMPANIES

Health care providers are relying on billing companies to a greater degree in assisting them in processing claims in accordance with applicable statutes and regulations. Additionally, health care professionals are consulting with billing companies to provide timely and accurate advice with regard to reimbursement matters, as well as overall business decision-making. As a result, the OIG considers compliance program guidance to third-party medical billing companies particularly important in efforts to combat health care fraud and abuse.

 

Further, because individual billing companies may support a variety of providers with different specialties, OIG recommend that billing companies coordinate with their provider-clients in establishing compliance responsibilities. OIG has identified specific areas of third-party medical billing company operations that may prove to be vulnerable to fraud and abuse.

The OIG guidance directs billing companies to focus on the following seventeen (17) risk areas, both in their own and their clients’ operations:

 

  1. Billing for items or services not actually documented;
  2. Unbundling;
  3. Upcoding, such as for example, billing for a higher level of visit code when a lower level has been done;
  4. Inappropriate balance billing;
  5. Inadequate resolution of overpayments;
  6. Lack of integrity in computer systems;
  7. Computer software programs that encourage billing personnel to enter data in the fields indicating services were rendered that were not actually performed or documented;
  8. Failure to maintain the confidentiality of information/records;
  9. Knowing misuse of provider identification numbers, which result in improper billings;
  10. Outpatient services rendered in connection with inpatient stays;
  11. Duplicate billing in an attempt to gain duplicate payment;
  12. Billing for discharge in lieu of transfer;
  13. Failure to properly use modifiers;
  14. Billing company incentives that violate the anti-kickback statute or other similar federal or state statute or regulation;
  15. Joint ventures;
  16. Routine waiver of copayments and billing third-party insurance only; and
  17. Discounts and professional courtesy.

 

To avoid above risk areas OIG suggest few recommendations. Although these recommendations include examples of effective policies, each billing company should develop its own specific policies tailored to fit its individual needs. The policies must create a mechanism for the billing or reimbursement staff to communicate effectively and accurately with the health care provider.

Policies and procedures should:

 

 

 

References:

  1. Office of Inspector General (OIG), Federal Register / Vol. 63, No. 243, Third party PDF. Retrieved from https://oig.hhs.gov/fraud/docs/complianceguidance/thirdparty.pdf

 

  1. Brian Mahany (2016, November 15), Medical Billing Companies Can Be False Claim Targets. Retrieved from https://www.aapc.com/blog/36813-medical-billing-companies-can-be-false-claim-targets/
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