Corporate Compliance

Hospital must improve cardiac rehabilitation billing

Compliance Monitor, August 27, 2003

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A Wisconsin hospital received approximately $47,247 in improper Medicare payments for outpatient cardiac rehabilitation services. The hospital, Saint Luke's Medical Center (SLMC), tripped up by not supporting patient eligibility for cardiac rehabilitation in the medical records. It also billed multiple units of service for a single cardiac rehabilitation visit, and inadequately documented outpatient cardiac rehabilitation services, according to a recent Office of Inspector General (OIG) audit report.

SLMC also did not designate a physician to directly supervise the services provided by its cardiac rehabilitation program or identify the physician professional services to which the cardiac rehabilitation services were provided "incident to," according to the OIG.

The OIG recommends that SLMC do the following to improve its billing compliance:

  • Work with United Government Services (UGS), SLMC's fiscal intermediary, to ensure that SLMC's outpatient cardiac rehabilitation program is being conducted in accordance with the Medicare coverage requirements for direct supervision and for services provided "incident to" a physician's professional services
  • Work with UGS to establish the amount of repayment liability for services SLMC provided to beneficiaries, without adequately documenting the medical necessity of the services
  • Bill only one unit of service per beneficiary for each cardiac rehabilitation session
  • Implement controls to ensure that medical record documentation is maintained to support Medicare outpatient cardiac rehabilitation services
  • Implement controls to ensure only Phase II (outpatient) cardiac rehabilitation services are billed to Medicare

    To read the audit report "Review of Outpatient Cardiac Rehabilitation Services at Saint Luke's Medical Center in Milwaukee, Wisconsin," click here.



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