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Posts Tagged ‘OIG’

OIG Releases Revised Provider Self-Disclosure Protocol

In Uncategorized on August 27, 2013 at 6:18 pm

The Department of Health and Human Services, Office of Inspector General (OIG) recently released a revised  Provider Self-Disclosure Protocol, updating the earlier version originally released in 1998 (see the following link:  https://oig.hhs.gov/compliance/self-disclosure-info/files/Provider-Self-Disclosure-Protocol.pdf).

Providers who wish to voluntarily disclose “self-discovered evidence of potential fraud to OIG may do so under the Provider Self-Disclosure Protocol (SDP).”  Self-disclosure does not absolve a provider of responsibility for potential fraud, but it does provide the opportunity for health professionals to avoid some of the costs associated with civil or administrative litigation.

In releasing the update, the OIG stated, “OIG endeavors to work cooperatively with providers who are forthcoming, thorough, and transparent in their disclosures in resolving these matters. While OIG does not speak for the Department of Justice or other agencies, OIG consults with those agencies, as appropriate, regarding the resolution of SDP matters.”

In 1998, the OIG published the original Provider Self-Disclosure Protocol to establish a process for health care providers to voluntarily identify, disclose, and resolve instances of potential fraud involving the Federal health care programs. The SDP was crafted to provide guidance on how to investigate this conduct, quantify damages, and report the conduct to OIG to resolve the provider’s liability under civil monetary penalty (CMP) authority.

Since the original Self-Disclosure Protocol was published, the OIG has identified several areas where additional guidance would be beneficial and could improve the efficient resolution of SDP matters. On the basis of the agencies experience and comments received from the public over the years, the OIG decided to revise the SDP in its entirety.

The new Protocol supersedes and replaces the 1998 Federal Register Notice and the associated “Open Letters” that have served to provide additional guidance to providers.

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Expect Heightened Review of Use of Modifiers -24, -25, -57, and -59

In Uncategorized on August 22, 2013 at 6:01 pm

Just a reminder to be careful with modifier use!

In 2012, the Medical Society of Virginia (MSV) was given advance notice that Anthem would soon begin targeting claims filed using modifiers 24, 25, 57 and 59.  Physicians who regularly use these modifiers should have also received a letter from Anthem requesting documentation to support the use of these modifiers.  Specialties that will be most affected include dermatology and orthopaedics.  Physicians may soon see similar efforts from other carriers as these targets are consistent with the Office of the Inspector General’s 2012 Work Plan.  Please contact MSV’s physician advocacy team at practiceservices@msv.org with any questions.