Corporate Compliance

Gov’t audit insider 1/20/03

Healthcare Auditing Weekly, January 20, 2004

As part of its national assessment, the Office of Inspector General (OIG) reviewed the reimbursement system for outpatient cardiac rehabilitation services at Cooley Dickinson Hospital in Northampton, MA. The OIG examined the hospital's policies and procedures for compliance with Medicare regulations for direct physician supervision, "incident to" services, and Medicare covered diagnoses. The OIG also determined whether payments for services were for Medicare covered diagnoses, were supported by adequate documentation, and were otherwise acceptable.

The OIG reviewed documentation, inpatient medical records, attending physician records, and Medicare reimbursement data for a sample of 15 beneficiaries who received outpatient cardiac rehabilitation services. It also interviewed staff to help it do the following:

1. Compare the hospitals' current policies and procedures to Medicare coverage requirements

2. Document how hospital staff provide direct physician supervision

3. Verify that the qualifications of the program's personnel complied with Medicare requirements

4. Check the availability of advanced cardiac life support equipment in the cardiac rehabilitation exercise area

Follow the OIG's lead and hold a similar audit in your organization. For each beneficiary who receives outpatient cardiac rehabilitation services at the hospital, try what the OIG did here:

1. Compared the hospital's documentation to the calendar year 2001 Medicare outpatient cardiac rehabilitation paid claims and lines of service

2. Reviewed medical records for compliance with "incident to" requirements

3. Verified the accuracy of the claim diagnoses with the corresponding inpatient medical record, physician referral, and the outpatient rehabilitation medical record

4. Determined whether the number of services Medicare reimbursed the hospital was beyond the maximum

Click here to read the audit report called "Review of outpatient cardiac rehabilitation services at the Cooley Dickinson Hospital."

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