Incorrect inpatient rehabilitation facility (IRF) claims led to $444,458 in overpayments at Memorial University Medical Center, a Savannah, Georgia-based hospital, according to a recent Office of Inspector General audit report. IRF billing compliance has been on the OIG’s radar for several years, and Medicare Administrative Contractors and supplemental medical review contractors have been placing these claims under increased scrutiny.
In the current healthcare climate, the issue of medical necessity documentation, or lack thereof, is one of the most common reasons for claim denials. For a service to be considered medically necessary (by a third-party payer), it must be considered a reasonable and necessary service to diagnose and/or treat a patient’s current and/or chronic medical condition.
One of the most memorable sessions at the AMA CPT Symposium in November 2017 involved an impromptu open mic feedback session facilitated by CMS’ Marge Watchorn, deputy director of the Division of Practitioner Services. The focus of this session was the applicability of the current CMS documentation guidelines for E/M services.
In the 2018 OPPS final rule, CMS finalized a change to the current clinical laboratory date of service policies for outpatient molecular pathology tests and advanced diagnostic laboratory tests.
CMS, the Veterans Health Administration, and some states measure our care quality based on risk-adjusted readmission rates after inpatient admissions. In fact, up to 3% of our hospital’s Medicare inpatient revenue (used to pay physician subsidies) is at risk if we don’t manage our patients’ readmissions in concert with Medicare’s algorithms.
