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Model Compliance Plan for Physician PracticesThe Office of the Inspector General (OIG) is developing a model compliance plan for physician practices. The draft is expected to be released this spring.
The compliance risk areas that are identified in the draft compliance plan include:
1. Billing services not rendered
2. Upcoding
3. Unbundling of services
4. Double billing
5. Billing for physician services rendered by non-physician providers
6. Medical necessity for services provided
7. Misrepresenting diagnoses to justify services
8. Completing certificates of medical necessity for patients not personally or professionally known to the physician
9. Billing Medicare or Medicaid for investigational research, medications, and/or procedures without proper authorization
10. Billing for non-covered services as if they were covered by an insurance program
The Health Care Financing Administration currently plans to continue to monitor physician practices with requests for documentation either on a pre-payment or post payment basis. In addition, HCFA is requiring that its local contractors profile physician-billing practices for possible outliers in billing behavior.
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