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the Office of the inspector General (OIG) released its work plan 2014 in late January. The 2014 OIG Work Plan includes physical therapy. Physiotherapists in private practice have again been identified as part of the scope of work.
This topic is in progress for several years so it is not surprising that physical therapy will be in the crosshairs again. Comments will be ongoing and this work is already underway for the 2013 Work Plan (which also represented a continuation of the work plan 2012). The 2014 Plan also indicate a new start. The reviews will be conducted by the OIG Office of Audit Services. Breathe a sigh of relief - it is the auditors, not investigators! Audits of BIG for physiotherapists in private practice will target the billing and payment to determine if they are in compliance with Medicare reimbursement regulations.
physical therapists Haute-use external physiotherapy
billing and payments. We will review the outpatient physical therapy services provided by independent therapists to determine whether they were in compliance with the Medicare reimbursement regulations. IGO-work Background Before that the claims of therapy services offered by independent physical therapists are not reasonable or medically necessary or are not properly documented. Our goal is to independent therapists who have a high utilization rate for outpatient physical therapy services. Medicare will not pay for items or services that are not "reasonable and necessary." (Social Security Act § 1862 (a) (1) (A).) The documentation requirements for therapy services are in CMS, policy Manual Medicare benefits, Pub. No. 100-02, c. 15, § 220.3. (OAS; W-00-11-35220, 00-12-35220-W, W-00-13-35220; various examinations, date of issue :. FY 2014, work in progress and new start)
Cross your fingers and hope your number is drawn. Well, that is something we all want, but the best idea is to be prepared, starting with having an active compliance program in place that not only provides an overview of Medicare billing and payments for all employees, but more important oversight to ensure that everything was done as planned. This includes an active compliance cycle: DETECT, CORRECT and PREVENT
OIG 2014 Work Plan includes physical therapy - What should I do
The good news ( if.? you can call it that) is that the OIG has issued a report last year about Spectrum Rehabilitation. This report includes witness information on how IGOs and verification approaches, and details of the results related to outpatient rehabilitation. This review included the audit staff of the OIG and many medical examiners supplier MAC
If you are a therapist in private practice are the things that should be on top of your to do list :.
- Have an active and effective compliance program in place . A compliance program is based on a compliance plan. If you do not have a compliance plan - quickly change the implementation of a plan the size of your practice and start with a risk assessment, a code of conduct and an employee training program, so that everyone understands and knows the behavior expected Medicare billing, coding and documentation rules. The presence of an active compliance program demonstrates a commitment to do the right thing, and it is necessary under the ACA (although the regulation has not been published). The best practice is to follow the advice of the OIG compliance guidance for doctors and small practices.
- consider the report of the OIG rehabilitation spectrum. After completing the report select some categories and audit to audit the reply in your own practice. Keep in mind that these are not quality assurance, regulatory compliance but, as noted requirements related to the "Status" (which is the status of Social Security - or the "Act"). My suggestions would be to approach the care certification plan, ensure that the billing provider is the rendering provider, and the minute therapy are correctly calculated two ways (time codes and the total processing time).
This is the super bowl weekend - so take time to enjoy at the root of your team, or to enjoy commercials and half time show. But come Monday morning, join me on Monday, monitor, as we are pleased to have bills Erin, Director of External Affairs of the OIG as our special guest to talk about the 2014 work plan
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Nancy Beckley
Nancy J. Beckley is the president of Nancy Beckley & Associates LLC, a firm specializing in compliance outpatient treatment. The firm offers outsourcing the compliance risk assessment, compliance plan development, annual compliance training, and external audit, due diligence and investigative support. Customers are suppliers under Medicare review of the probe, the plans of progressive corrective actions, corporate integrity agreements, ZPIC investigations and RAC audits.
Nancy background includes 15 hospital years experience in the service management capabilities to two large rehabilitation facilities for inpatients with extensive managed care contracting and program management expertise. A therapist in the background and training, Nancy served as program director, director of the institution and administrator in both rehabilitation facilities for inpatients and outpatients.
She is a nationally recognized speaker in the field of rehabilitation of compliance, and presented to the Conference Provider Practice Compliance, Florida Compliance Conference, and the Healthcare Compliance Compliance Institute Association. It was described in a Healthcare Compliance Association webinar on the risk of hospitalization in outpatient therapy, and wrote three articles for compliance Today and written over 20 articles on the RAC program.
Mrs. Beckley area of expertise includes:.
• Development of the compliance program, consulting, training, and the external auditor
• Medicare Regulatory requirements for suppliers outpatient therapy, including extensive experience in the investigation and Medicare certification for outpatient treatment providers
• auditing and consulting commitments under attorney-client privilege for risk assessment and the analyzes the potential recovery of responsibility
• Medicare program integrity initiatives: MACs, RACs, CERTs, ZPIC, critics of the probe before and after payment of examinations
• recognized expert national level on CORFs, served on the technical expert Group Medicare CORF
• outpatient Hospital board compliance, audit and training
• compliance diligence activities due in the acquisition and portfolio development to assess compliance risk Medicare
EDUCATION: University of South Florida, MBA; Harvard School of Public Health course for managed care executives; University of Illinois, m.s. University of Wisconsin, B. s
PROFESSIONAL ASSOCIATIONS: Board of Directors, National Association of Rehabilitation Agencies (NARA) Members, Healthcare Compliance Association; Contributing Editor principal RAC Monitor + monitor Monday; Compliance columnist for IMPACT Journal of APTA
PROFESSIONALCERTIFICATIONS: CHC, certified Health compliance by the Healthcare Compliance Certification Board
PUBLICATIONS AND PRESENTATIONS: Available on request
CONTACT: 414-748 -4376; Nancy@NancyBeckley.com;
Latest posts of Nancy Beckley (see all )
- Call Medicare Denials - 5 things you need to know - June 18, 2014
- therapy PQRS Panic - June 5, 2014
- Medicare Confusion G code - May 28, 2014
- Medicaid exclusion controls - May 7, 2014
- Checking Importance Exclusions - April 30, 2014
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