January 31, 2014
The HHS Office of the Inspector General releases 2014 Work Plan
The Department of Health and Human Services (HHS) Office of the Inspector General (OIG) has released its 2014 work plan. The OIG work plan includes a list of the issues the OIG intends to review in the upcoming year to address concerns about improper billing and/or payments.
As was the case in the 2013 work plan, anesthesia services are specifically cited in the 2014 work plan:
"Anesthesia services—Payments for personally performed services.
Billing and Payments. We will review Medicare Part B claims for personally performed anesthesia services to determine whether they were supported in accordance with Medicare requirements. We will also determine whether Medicare payments for anesthesiologist services reported on a claim with the “AA” service code modifier met Medicare requirements. Context—Physicians report the appropriate anesthesia modifier code to denote whether the service was personally performed or medically directed. (CMS, Medicare Claims Processing Manual, Pub. No. 100-04, ch.12, § 50) Reporting an incorrect modifier on the claim as if services were personally performed when they were not will result in Medicare’s paying a higher amount. The service code “AA” modifier is used for anesthesia services personally performed by an anesthesiologist, whereas the QK modifier limits payment to 50 percent of the Medicare-allowed amount for personally performed services claimed with the AA modifier. Payments to any service provider are precluded unless the provider has furnished the information necessary to determine the amounts due. (Social Security Act, §1833(e).) (OAS; W-00-13-35706; various reviews; expected issue date: FY 2014; new start)"
Review a copy of the 2014 work plan.