By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
On July 2, 2012 the Officer of Inspector General (OIG) released its Medicare compliance review of West Florida Hospital in Pensacola. According to the audit, the hospital complied with Medicare billing requirements for the documentation majority of inpatient and outpatient claims. However, the overpayments for the years 2009 and 2010 totaled up to $173,000.
Official Break Down of the Audit.
West Florida Hospital complied with Medicare billing requirements for 151 of the 208 inpatient and outpatient claims that were reviewed. According to the OIG, the hospital did not fully comply with all Medicare billing requirements for the remaining 75 claims, resulting in overpayments totaling $173,000 for 2009 and 2010. Specifically, 55 inpatient claims had billing errors, resulting in overpayments totaling $145,000, and two outpatient claims had billing errors, resulting in overpayments totaling $28,000.
From our experience in this area of health law, for a hospital, this as an excellent outcome.
OIG Suggests Overpayment issues Were Due to a Lack of Sufficient Controls to Prevent Incorrect billing.
OIG officials said the hospital lacked sufficient controls to prevent incorrect billing and the staff did not fully understand the billing requirements. The OIG report recommended West Florida Hospital provide training to its staff to avoid confusion regarding billing requirements.
To see the full audit of West Florida Hospital, click here.
Meanwhile in a separate review, the OIG found that Palmetto General Hospital in Hialeah, Fla., generally complied with Medicare billing requirements except for billing errors in 15 claims, resulting in overpayments totaling $125,000 in 2009 and 2010.
The audit report stated most of these overpayments were a result of human errors. The OIG suggested Palmetto General Hospital tighten its controls to more sufficiently comply with billing requirements.
The Centers for Medicare & Medicaid Services (CMS) Plans to Cut Down on these Incidents with the Recovery Audit Prepayment Review (RAPR) Demonstration Project.
To cut down on these incidents, the Centers for Medicare & Medicaid Services (CMS) announced it would move forward with the Recovery Audit Prepayment Review (RAPR) Demonstration Project this summer.
This review will allow Recovery Audit Contractors (RACs) to review claims before they are paid to ensure that the provider complied with all Medicare payment rules. The RACs will conduct prepayment reviews on certain types of claims that have been found to result in high rates of improper payments.
To learn more on the RAPR Demonstration Project, click here.
Unfortunately, our experience has been that prepayment review is unfairly onerous, slowing down or shutting off Medicare claim payments and tremendously increasing the costs of claims processing for Medicare provider (in personnel time, photocopying costs and postage). In the case of smaller Medicare providers, this often results in putting them out of business.
OIG.HHS.Gov. “Medicare Compliance Review of West Florida Hospital for Calendar Years 2009 and 2010.” The Office of the Inspector General. (July 16, 2012). From: http://oig.hhs.gov/oas/reports/region4/41108010.asp
Floyd,Allison. “Hospital Overpayments Due to Billing Confusion, Human Errors, OIG Finds.” Firce Healthcare. (July 16, 2012). From: http://www.fiercehealthcare.com/story/hospital-overpayments-due-billing-confusion-human-errors-oig-finds/2012-07-16#ixzz21et2TaQO
About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.
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