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ASA NEWSLETTER
 
 
August 1996
Volume 60
Number 8
 
PRACTICE MANAGEMENT

Ophthalmologist Convicted of Fraudulent Billing, Sentenced to Prison Time

Karin Bierstein
Practice Management Coordinator



Many anesthesiologists have registered their concerns over a recent article on the op/ed page in The Wall Street Journal suggesting that innocent billing errors could land a physician in prison under proposed revisions to the Medicare fraud and abuse laws. Last January's conviction of a Montana ophthalmologist for inflating nurse anesthetist time was based on facts showing willful and intentional fraud. Contrasting the behavior that resulted in an actual prison sentence with the hypothetical violations in the op/ed article -- rendering services of equivocal medical necessity, single instances of incorrect coding -- should provide a reasonable perspective on the enforcement of the fraud and abuse laws.

In United States v. Erickson, which the U.S. Supreme Court declined to review on May 28, Bruce L. Erickson, M.D., and co-defendant Great Falls Eye Surgery Center were convicted by a jury of knowingly and willfully overbilling Medicare and Medicaid patients. Dr. Erickson, who had lost privileges at a local hospital, was a 50-percent owner of the eye surgery center. The center had started operations in 1989 and had first come to the attention of the Health Care Financing Administration (HCFA) in 1990. The HCFA agent who investigated the center's billing practices in 1991 found that the center routinely charged Medicare for overlapping nurse anesthetist services, billing as many as 27 hours for the services of a single nurse anesthetist in a 10-hour workday.

In 1992, the center had changed the way it billed Medicare after consulting with another eye surgery institution in Utah. The new system recorded continuous back-to-back blocks of nurse anesthetist services, with the anesthesia time for one patient beginning immediately after the anesthesia time for another patient had ended. This suggested to the HCFA agent that the billing periods must include pre- and/or postoperative stretches of time when the nurse anesthetist was away from the patient. Apparently, the defendants acknowledged that the patients were not continually attended, since they chose to challenge the Medicare regulation stating that "time units involve the continuous actual presence of the physician..." as being unconstitutionally vague. The Court of Appeals disagreed, however. It found that both on its face and as commonly understood by other providers:

"the regulation clearly limits CRNA [certified registered nurse anesthetist] reimbursement to periods when the CRNA is actually with and looking after the patient. The regulation requires 'personal attendance' that is said to cease when the patient is placed in the care of another."

The court also rejected arguments regarding jury selection, various evidentiary rulings and the jury instructions. Accordingly, it upheld the convictions of both Dr. Erickson and the center but remanded to the district court for an explanation of why the district court had sentenced Dr. Erickson to just two months of prison time, instead of the 21 to 27 months stipulated in the federal sentencing guidelines.

It is clear that the conviction turned on the defendants' knowledge and intent to obtain Medicare reimbursement exceeding the value of the services actually provided. It is both fortunate and unfortunate that there are enough instances of intentional fraud that the government is unlikely to pursue improper billing arising from genuine confusion or ambiguities in the rules.

As this column is written, Congress still has not taken final action on health insurance reform legislation, one portion of which clarifies the requirement that both knowledge and intent be present to establish Medicare fraud. The provision as drafted by the Republican leadership appears generally satisfactory, especially in that it permits physicians, for the first time, to seek advisory opinions on ambiguities in the Medicare rules.

Financial Arrangements With Hospitals: Are You Being Asked for Illegal Kickbacks?

Hospitals are increasingly viewing anesthesiologists and other hospital-based specialists as a source of potential revenue. Stipends and other payments to anesthesiologists for management and coverage or for on-call services provided to the hospital have been reduced or eliminated. Radiologists have been asked to buy high-priced and duplicative practice management services from the hospital. The ASA Washington Office has heard a report of at least one hospital requiring the anesthesiologist to pay a large annual "rental" fee in exchange for an exclusive contract.

All of these forms of payment to hospitals violate the federal anti-kickback statute, section 1112B(b) of the Social Security Act. The anti-kickback law makes it illegal to offer, pay, solicit or receive remuneration for referring patients or for arranging for or recommending the ordering of any service payable under Medicare or Medicaid. This broad language covers indirect as well as direct forms of remuneration and places both the recipient and the payer (i.e., the physician) in violation.

In 1991, the Inspector General of the Department of Health and Human Services issued a Management Advisory Report, "Financial Arrangements Between Hospitals and Hospital-Based Physicians," which listed examples of questionable arrangements, such as:

* A radiologist group pays 25 percent of the profits exceeding $120,000 to the hospital for capital improvements. Fifty percent of the profits exceeding $180,000 go toward this purpose.

* A hospital provides no, or token, reimbursement to pathologists for Medicare Part A services in return for the opportunity to perform and bill for Part B services at that hospital.

The report concluded: "All of these examples appear to violate the statute because they provide compensation to the hospitals that exceeds the fair market value of the services the hospitals provide under the contracts." Analysis of all the circumstances surrounding the agreements would be necessary to establish actual violations.

If you are asked to forgo fair market value payment for your services to the hospital or for monetary contributions to a hospital fund as a condition of being allowed to provide anesthesia services to Medicare/Medicaid patients, you may want to ask that the hospital give you a formal legal opinion, in writing, on the lawfulness of the arrangement.

Copies of the Inspector General's Management Advisory Report can be obtained from Joan Heffernan in the ASA Washington Office at (202) 289-2222.

Do Exclusive Contracts for 'Anesthesia' Services Encompass Pain Medicine?

The ASA Washington Office occasionally receives calls from members who want to know whether the existence of a contract giving one anesthesiology group the exclusive right to provide anesthesia services for the hospital's patients can legitimately preclude other anesthesiologists from practicing pain medicine at that hospital.

In most states, courts have upheld hospital exclusive contracts and the consequent denial of privileges to anesthesiologists not affiliated with the group that has the contract. Some of our callers are hoping to make the argument that the exclusive contract does not affect privileges for anything other than "anesthesia services" narrowly defined. Others contend that "anesthesia services" should be broadly defined so as to prevent newcomers from performing any medical services provided (actually or potentially) by the incumbent group.

As far as we know, there are no statutory or regulatory provisions that would favor one view or the other, and therefore, general rules of contract interpretation govern. The inclusion of pain codes in the ASA Relative Value Guide, which has the subtitle "A Guide for Anesthesia Values," provides at least some indirect evidence of a consensus on a broad definition of anesthesiology. It would seem difficult, though not necessarily impossible, to establish that the hospital and the group with the exclusive contract intended to exclude pain management, critical care or any other services that anesthesiologists might commonly provide unless the parties said so.

The moral here appears to be that anesthesiologists negotiating and drafting exclusive contracts might wish to circumscribe any future disputes over the extent of the exclusivity by spelling out all of the services they mean to cover. Lawyers are regularly criticized for the length of their documents; perhaps here we have an example of why a few more words in the contract would sometimes be helpful to all concerned.

Calculating Anesthesia Capitation Rates
Manual Now Available

ASA's new Practice Management manual, Calculating Anesthesia Capitation Rates, is now available for purchase. This manual describes one method for calculating profit, loss and per-member-per-month fees for a capitation proposal in an anesthesia practice. The reader is guided step by step through numerous examples. The manual provides an extensive discussion of data (and adjustments) required for a capitation proposal.

Calculating Anesthesia Capitation Rates is available for $40 per copy, which includes shipping and handling (Illinois residents add 7.75 percent sales tax). All publication orders must be prepaid and should be forwarded to the ASA Publications Department, 520 N. Northwest Highway, Park Ridge, IL 60068-2573.

1997 Practice Management Conference Scheduled

The third annual Practice Management Conference will take place in Orlando, Florida, on Friday through Sunday, February 21-23, 1997. Plan to register early -- the Phoenix (1995) and New Orleans (1996) conferences were sellouts. Among the new topics that will be addressed are Medicare fraud and abuse law and its enforcement. The importance of this topic is borne out by the $42 million-plus netted by the government in the first year of its new health fraud enforcement program, Operation Restore Trust.

 


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