The Office of the Inspector General for the Department of Health and Human Services is casting a wary eye at billing practices that appear to represent double billing for radiological services.
While it's not certain whether the OIG will identify a violator and enforce penalties, providers need to know that the practice is on the agency's radar screen, industry observers say.
This type of case is just the kind the OIG likes to pursue, said Joe Lineberry, vice president of compliance and regulatory affairs at Per-Se Technologies in Alpharetta, Ga., at the recent Radiological Society of North America's annual conference in Chicago.
Last year, the OIG reported that it had found $20 million in potential overpayments between 2001 and 2003.
The duplicate payments occur during a Medicare patient's hospital stay, when the facility receives a prospective payment from Medicare under Part A. That payment is supposed to cover non-physician radiology services, while the physician component of those services is paid under Medicare Part B. Overpayments occur when Part B is additionally billed for non-physician radiology services.
The OIG has recommended that CMS instruct Part B carriers to recover overpayments, use information technology to identify inappropriate billings and educate physicians through carriers about improper billing practices.
It's not clear how quickly the OIG will step up enforcement of the practice. It's mentioned in the HHS OIG Work Plan for Fiscal Year 2007, although inclusion in the work plan does not guarantee OIG activity.
Lineberry suggested providers start cleaning up billing practices. He said the OIG likes to pursue these types of cases because the illegality is easy to explain to the public and easy to prove.
In addition, claims filed for interpreting diagnostic X-rays in the emergency department also could be subject to scrutiny, Lineberry said. It's a big expense for Medicare, as some 2.5 million diagnostic X-rays were performed in 2004.
X-rays often are interpreted by a physician in the emergency department, and in some cases by a second radiologist to confirm the first interpretation. Medicare is concerned about receiving bills for both interpretations and will be looking for supporting documentation that warrants the second review, Lineberry said.
Finally, OIG will continue to review the propriety of referrals for imaging services to independent freestanding radiology facilities, making sure that physicians making the referrals aren't making decisions based on any vested financial interest.