OIG updates laboratory compliance plan
OIG updates laboratory compliance plan
In addition to issuing its home health plan, the OIG has updated its model compliance plans for clinical labs. The biggest change is removing requirements regarding automated multichannel chemistry tests (CPT codes 80002-80019).
Labs will no longer have to worry about educating physicians about automated tests. For example, the new model plan no longer requires labs to write requisition forms so doctors would have to order tests individually. The new plan merely calls for the form to ask that a doctor "has made an independent medical necessity decision with regard to each test the laboratory will bill."
Nor will annual notices sent to doctors by labs have to break down the individual components of every multichannel test. However, labs still must remind physicians of Medicare policies on lab tests and the consequences of filing a false claim.
In other ways, the lab model plan has been brought into line with newer plans for hospitals and home health agencies. A major change is that OIG has dropped the controversial standard of requiring self-disclosure within 60 days after the receipt of the credible evidence of misconduct.
In the updated plan, the clock starts ticking after you have had time to conduct an internal investigation, rather than beginning immediately after an employee reports a suspicion of misconduct.
An important addition concerns Advanced Beneficiary Notices, which tell beneficiaries that they may have to pay for a service that might be denied. The agency recommends labs educate physicians on the use of ABNs, which must specifically list the service in question and why Medicare might not pay.
Other changes in the new plan include:
- Expanded duties for lab compliance officers. Compliance officers should review requisition forms and other documents that support claims, as well as check lab forms that doctors and others use to order tests.
- Obtaining diagnoses. Labs should ask doctors to provide diagnostic information when ordering tests, says OIG. Even though physicians should be doing that routinely for most tests, it’s important for labs to ask for the data because they are obligated to produce documentation to support medical necessity.
- New employees. New hires should sign a statement certifying they have read and understood the lab’s standards of conduct.
- New ways of obtaining data. The plan states that additional information, such as diagnosis data from the medical record, "can be obtained from an authorized person on the physician’s staff rather than directly from the physician."
- Physician’s discretion. The new plan makes clear that doctors can order whatever tests they deem appropriate. But Medicare will only pay for those that are covered, reasonable and necessary.
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