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Risky business: Where you’re most likely to make a billing error

Helpful tips from HHS’s Office of Inspector General on how to sidestep mistakes that may keep you from getting paid.

HHS’s Office of Inspector General is doing doctors a favor. In Compliance Program Guidance for Individual and Small Group Physician Practices, it lists the most vulnerable aspects of doing business–areas where mistakes are most likely to be made.

•Coding and billing: Billing for services not rendered or items not provided. Submitting claims for equipment, medical supplies, and services that aren’t reasonable and necessary. Double billing. Billing for noncovered services. Misusing a provider identification number. Unbundling. Clustering. Upcoding.

•Reasonable and necessary services: Services not covered by Medicare, Medicaid, or other appropriate federal program.

•Documentation: Incomplete information. Illegible information. Data nonsupportive of CPT and ICD-9 codes.

•Improper inducements, kickbacks, and self-referral: Financial arrangements with entities to whom the practice may refer federal health care program business. Joint ventures with companies that supply goods and services to the practice. Consulting contracts and medical directorships. Office and equipment leases with companies to which the practice refers. Accepting or offering gifts or gratuities of more than nominal value to those who may receive a practice’s referrals.

—Michael Pretzer
Washington Editor

For a more in-depth look at compliance plans, see "Compliance plans: How optional, really?" See also, "What one doctor has done about compliance."

Michael Pretzer. Risky business: Where you're most likely to make a billing error.

Medical Economics

2001;2.