HHS OIG Releases Work Plan for FY 2008

U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has released its work plan for FY 2008. The plan includes several areas of interest in the section on physicians, a number of which relate to pain services:

1. Place of service errors: The focus is on physician coding of the place of service for services performed in ASCs and hospital outpatient departments.
2. Evaluation and Management (E&M) Services during global surgery periods: The global surgery payment includes E&M services provided during the global surgery period. The OIG will determine whether industry practices related to the number of E&M services provided during the global surgery period have changed since the global surgery concept was developed in 1992. Anesthesiologists who try to bill E&M services within the global period of the acute post-op pain services they provide may find that their services come under review. 
3. Medicare payments for selected physician services: The description of this area of inquiry is not sufficiently specific to assess whether it will be of interest to ASA members. The OIG will review the appropriateness of Medicare Part B payments for selected physician services such as consultations. 
4. Medicare “incident to” services: The OIG will review Medicare claims for “incident to” services for unspecified selected physicians. Since “incident to” services are billable only in the office setting, this area of inquiry may be of greatest interest to pain physicians. 
5. Assignment rules: The OIG will review whether Medicare providers are complying with the assignment rules in billing Medicare beneficiaries. Participating physicians cannot charge Medicare beneficiaries more than the deductible and coinsurance amounts. Most anesthesiologists are required by the hospitals at which they provide services to participate with Medicare. 
6. Medicare payments for interventional pain management procedures: This area is likely to be of substantial interest to ASA members who provide pain management services. The OIG focus is to determine the appropriateness of Medicare payments for interventional pain management procedures and to assess the oversight of these procedures. 
7. High utilization of ultrasound services: The OIG will review services and billing patterns in geographic areas with high utilization of ultrasound services, including service profiles, provider profiles, and beneficiary profiles. The review will examine disproportionately high percentages of Medicare beneficiaries receiving ultrasound services relative to the rest of the country. This focus area may be of interest to anesthesiologists, since the use of ultrasound guidance for peripheral nerve blocks has been increasing. 
8. Physician reassignment of benefits: The OIG will review whether physicians are complying with Medicare reassignment rules. The OIG will examine a national sample of physicians to determine the extent to which they reassign their benefits to other entities and the extent to which physicians are aware of reassignments requested on their behalves.

ASA will monitor these issues and post additional information as it becomes available.