Expect POS Audits for 2008 and 2009 Services

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The OIG audited a sample of 100 claims that were submitted to Medicare in 2008 and found that 89 of 100 of the claims for non facility place of service codes were incorrectly coded, in addition 83 of the 100 claims audited for 2009 were incorrectly coded. What they found that in these 172 claims were actually performed in a hospital outpatient department or ACS and they were codes as a non facility POS. For this small group of claims it was determined that there were overpayents totaling $4639 in 2008 and $2979 in 2009 . Extrapolating this OIG has estimated that Medicare overpaid physicians $19.3 million in 2008 and $9.5 million in 2009 for services that were provided in a facility but were incorrectly coded.

Based upon their audit, OIG has concluded that the overpayments are due to internal control weaknesses at the physician billing level and to insufficient postpayment reviews at the Medicare contractor level to identify potential place-of-service coding errors.

OIG has recommended that the Centers for Medicare & Medicaid Services (CMS) instruct its Medicare contractors to

(1) recover approximately $5,000 in overpayments for the sampled services;
(2) immediately reopen the claims associated with the nonsampled services, review our information on these claims (which have estimated overpayments of $19.3 million), and work with the physicians who provided the services to recover any overpayments;
(3) continue to strengthen their education process and reemphasize to physicians and their billing agents the importance of correctly coding the place of service and the need for internal controls to prevent Medicare billings with incorrect place-of-service codes; and
(4) continue to work with program safeguard contractors and, if necessary to coordinate Part A and Part B data matches, with other Medicare contractors to develop a data match that will identify physician services at high risk for place-of-service miscoding and recover any identified overpayments.

CMS has concurred with the OIG recommendations and described the corrective actions that it was taking or planned to take.

The full reports can be read at :
2008 Report : http://www.cmeonline.com/sites/default/files/downloads/2011/09/11000513.pdf
2009 Report : http://www.cmeonline.com/sites/default/files/downloads/2011/09/11000516.pdf