OIG Report Signals Likelihood of Increased Scrutiny of Evaluation and Management Coding

On May 8, 2012, the Office of Inspector General of the U.S. Department of Health and Human Services (OIG) published its first in a series of reports on evaluation and management (E/M) services billed under Medicare Part B. As described in this initial report, the OIG reviewed E/M coding trends by physicians from 2001 to 2010. The OIG also identified those physicians who consistently billed more complex and expensive (i.e., higher-level) E/M codes in 2010. The OIG found that, from 2001 to 2010, physicians increased their billing using higher-level E/M codes across all types of E/M services. From 2010 data, the OIG identified approximately 1,700 physicians who consistently billed using higher-level E/M codes. These physicians practiced in nearly all states and were of similar specialties. They also treated Medicare beneficiaries of similar ages and having similar diagnoses as those treated by other physicians. The OIG made no determination in this study as to whether such E/M claims were inappropriate, but it indicated that, in subsequent evaluations, it will do so. Accordingly, physicians can anticipate increased scrutiny of claims for E/M services, particularly where consistent use of higher-level codes is apparent from Part B claims data.

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