2009-11-04
The Centers for Medicare and Medicaid Services (CMS) has directed Medicare contractors to review claims data related to Medicare Part B chemotherapy administration and qualifications of non-physicians who performed Medicare physician services. This directive comes as a result of recent reports by the Office of the Inspector General (OIG) concerning whether Medicare paid appropriately for Part B services billed as chemotherapy administration from 2005-2007. A summary of the issues and links to the OIG reports follow:
- Issue: claims with code for chemotherapy administration but no chemotherapy drug reported on the same date of service
- Typically, when no drug is noted for the infusion code, it is because:
- Patient was indigent – The practice should be able to identify when this occurs, in case information is requested by CMS/RAC.
- Patient is on a clinical research trial – The practice should utilize the Q0/Q1 code.
- Prevalence and Qualifications of Non-physicians Who Performed Medicare Physician Services (OEI-09-06-00430)
- OIG recommended that CMS seek revisions to the “incident to” rule. The rule requires that physicians who do not personally perform the services they bill to Medicare ensure that no persons except licensed physicians personally perform the services or non-physicians who have the necessary training, certification, and/or licensure, pursuant to State laws, State regulations, and Medicare regulations personally perform the services under the direct supervision of a licensed physician.
- The practice should assure that if a non-MD provides the service that:
- The appropriate charge for a non- MD is submitted.
- The non-MD has the appropriate skills/knowledge and that the function falls within the scope of practice (which varies by state).
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