This week we will discuss recent developments concerning the OIG's Work Plan, CMS' National Coverage Determinations, and recent enforcement actions by the federal government for health care fraud and abuse. As always, please feel free to send questions, concerns, or suggestions via email.
Gregory B. Root, Esq.
2004 OIG Work Plan
Each year the OIG publishes a work plan for the coming year to indicate the types of issues and concerns it will investigate and possibly address through guidance or enforcement actions. Often times the work plan is a valuable source of guidance to providers concerning potential compliance issues. Other times the OIG lists the same action items year after year with little change or new information.
This year the OIG included in its work plan for 2004, an action item concerning the use of CPT coding modifiers to bypass or overcome CCI edits. Past Compliance Briefings have explained that CCI edits are controls used by carriers to automatically deny claims that are reported with CPT code pairs that are dee....
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