A report issued by the Office of the Inspector General (OIG) on May 6, 2015 found that Medicare overpaid physicians approximately $33.4 million for services performed in facility locations that were incorrectly coded as performed in non-facility locations, such as ambulatory surgery centers and hospital outpatient departments. The physicians identified in the audit will have to reimburse Medicare for the overpayments.
The OIG attributed the coding errors to “internal control weaknesses at the physician billing level and to insufficient postpayment reviews at the Medicare contractor level to identify potential place-of-service billing errors”. The report indicated that their review of this area would be ongoing, especially since so much was recovered from the previous audit.
Not long after the audit period, which included services from January 2010 to September 2012, the Medicare rules for reporting Place of Service codes changed dramatically. The April 1, 2013 changes to the rules can be summarized as follows:
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The use of Global Billing now depends on the location of the professional and technical component services as well as the relationship between the parties.
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When professional and technical components are billed separately, the Service Facility Location should reflect where the service was actually provided. In the case of a radiologist, this would be where the interpretation was completed.
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The fee schedule to be used for payment will depend on the actual location of the services, based on zip code. The fee schedule for the professional component may be different from that of the technical component.
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The Place of Service (POS) Code generally follows the location where the patient’s exam took place, even if the interpretation was performed remotely by teleradiology. This clarified the general treatment that has been in place for some time.
Because radiology images are often interpreted at a location separate from where the imaging took place, radiologists are perhaps already more aware of the need for correct place-of-service identification than are other physicians. Nonetheless, radiology groups that have not reviewed these rules recently should make sure that their billing and coding teams (internal or outsourced) are up-to-date on the issue and that their systems are compliance-ready in order to avoid the need to reimburse Medicare.
