OIG recommended review to get overpayments

Subject: APMA Daily eNews (No. 1,187)

APMA DAILY eNEWS
Wednesday, August 14, 2002 (No. 1,187)

Following a report (eNews 1,150) by the Office of the Inspector General
(OIG) of the US Department of Health and Human Services (HHS), the
Centers for Medicare & Medicaid Services has instructed carriers and
intermediaries to review nail debridement claims this fall. In Medicare
Program Memorandum AB-02-105 on July 31, CMS said:

"The Office of Inspector General has recommended that CMS conduct
medical review in order to identify and collect nail debridement
overpayments. You must periodically perform data analysis to detect
potentially inappropriate billing for nail debridement services. You
must target a medical review probe on specific providers or review
broadly on these services where data indicate the need. Follow the
Progressive Corrective Action process to obtain the corrective action.
Should those efforts result in the medical review of claims you must
recover any inappropriate payments."

APMA will vigorously object to CMS about this initiative because the
vast majority of podiatric physicians provides necessary and appropriate
foot and ankle health care services.

The OIG reported in June that 22.7 percent of reviewed nail debridement
claims did not have adequate documented justification. OIG estimated
$51.2 million was improperly paid for nail debridement in 2000. In
addition, Medicare paid an estimated $45.6 million for related services
that were also deemed inappropriate because the underlying nail
debridement was not supported by the medical record.

APMA Carrier Advisory Committee (CAC) and Private Insurance Advisory
Committee (PIAC) representatives discussed progressive corrective action
during the annual CAC/PIAC meeting last May.

APMA reminds podiatric physicians to accurately and thoroughly document
the medical necessity of podiatric medical services. The OIG
investigation focused on claims that were not supported by the medical
record.


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