October 21, 2013
Providers reassign Medicare and other third party benefits all the time. That is, they hand over individual provider numbers so that their employer entity can use it to bill and be paid for services rendered. Sounds like a perfect arrangement doesn’t it?
However, this is often completed as a matter of course without much thought to the implications of the power being bestowed on the employer. The physician can be found responsible for inappropriate, abusive or fraudulent billing if they knew or should have known the services being billed were inappropriate. Do you know what you employer organization billed as having been rendered by you?
On February 8, 2012 the OIG (Office of Inspector General) issued and alert that warned providers to be cautious about the organizations to which they reassign benefits. Medicare generally prohibits reassignment of benefits but a physician-employer contract is an exception to that prohibition. The OIG cautions that although the billing entity is responsible for any overpayments resulting from inappropriate billing, the physician has culpability as well.
According to the reassignment agreement as written by Medicare, the physician or the supplier of the service MUST have unrestricted access to the claims information submitted by the entity. That puts the burden of monitoring squarely on the physician’s shoulders. Physicians are expected to, obligated to, monitor the services that are being billed under their reassigned provider number.
While the examples in the OIG Alert seem extreme, the simple fact is, these providers did not monitor what was being billed out as having been rendered by them or under their supervision. What structure do you have in place to mitigate the risk associated with incorrect, inappropriate, or even fraudulent billing? Physicians must proactively monitor claims.
Read the Full alert from the OIG here: http://oig.hhs.gov/compliance/alerts/guidance/20120208.pdf