Based on a recent report from the Office of Inspector General (“OIG”), Medicare permitted $38 million of improper claims for interpretation and reports of radiology services based on insufficient documentation in hospital emergency departments in 2008. This includes a 19 percent erroneous allowance of claims for interpretation and reports for magnetic resonance imaging (“MRI”) and computed tomography (“CT”) and a 14 percent allowance of similar x-ray claims.
Lack of physicians’ documented orders (12 percent of MRI/CT claims, 8.6 percent of x-ray claims) and documentation verifying that interpretation and reports were performed (12 percent of MRI/CT claims, 8.2 percent of x-ray claims) were among the problems encountered. In some instances, overlapping documentation errors (5 percent of MRI/CT claims, 3 percent of x-ray claims) were found. Interpretation and reports claims were also allowed after the patients left the emergency department in a significant number of cases (12 percent of CT and MRI claims, 16 percent of x-ray claims).
In an effort to prevent the erroneous Medicare expenditure, the OIG recommended that the Centers for Medicare and Medicaid Services (“CMS”) educate healthcare providers regarding the documentation maintenance requirement for submitted claims, create a consistent policy that services of interpretation be contemporaneous with diagnosis or treatment or classify situations in which noncontemporaneous services are beneficial, and take proper action for wrongful claims identified in the report.
According to the OIG Office of External Affairs, CMS agreed with the first and third recommendations but rejected the uniform policy suggestion.