Q&A: Applying OIG requirements to policies and procedures

June 1, 2020
Medicare Web

Q: What are the Office of Inspector General's (OIG) recommendations for policies and procedures related to billing?

A: According to guidance set forth by the OIG specific to billing, policies and procedures developed by organizations should do the following:

  • Ensure accurate and timely documentation of all services prior to billing.
  • Emphasize that claims should be submitted with appropriate documentation that is maintained and available for audit and review. Such documentation may include patient records and should record the time spent performing the service that led to the entry, as well as the identity of the person providing the service. The hospital and its medical staff may wish to establish other documentation guidelines as appropriate.
  • Ensure that practitioner and hospital records and medical notes used as a basis for claim submissions are organized properly and legibly so they can be audited and reviewed.
  • Insist that diagnoses and procedures reported on reimbursement claims be based on medical records and other documentation. The documentation necessary for accurate code assignment should be made available to coding staff members.
  • Indicate that compensation for billing department coders and billing consultants should notprovide any financial incentive to upcode claims.

For more information, see The Compliance Officer's Handbook, Fourth Edition.