A compliance focus on the 2006 OIG Work Plan

To determine which areas of professional billing present the highest risk to your practice, it is recommended that physicians and their office staff review the Office of Inspector General's (OIG) annual Work Plan. The Work Plan details areas for increased scrutiny by the federal government due to a high rate of inappropriate billing, which has cost the Medicare program millions of dollars. The OIG's Work Plan for Fiscal Year 2006 identifies several new areas of investigation, but what is more curious is what is not on the OIG Work Plan for 2006. For the first time in several years, this year's Work Plan does not include investigations into evaluation and management services (E/M), including the controversial consultation codes. But don't let your guard down on E/M documentation as our local Medicare carrier has stated they will begin a widespread probe review into the hospital admit CPT code 99222. Documentation to support the billing of CPT 99222 must include a comprehensive history (including ten review of systems); a comprehensive examination of eight or more organ systems for the 1995 guidelines or two elements from each of nine systems of a 1997 multisystem exam; and moderate decision making. Medicare will also be requesting reviews on subsequent inpatient hospital care codes, CPT 99231, 99232 and 99233.