OIG offers guidance for dealing with consultants
OIG offers guidance for dealing with consultants
The Health and Human Services’ (HHS) Office of Inspector General (OIG) last week released a Special Advisory Bulletin on dealing with health care consultants that says the first thing providers should do to protect themselves when engaging consultants is to be alert for illegal or misleading representations.
For example, consultants may falsely claim they have "inside or special access" to the OIG or claim that their services or products are approved, certified, or recommended by Medicare or HHS.
The OIG warns providers to be alert for:
- Valuation consultants who promise that their appraisal of a physician’s practice will yield a fair-market value that satisfies a client’s demand for a particular valuation, regardless of the actual value.
- Billing consultants who claim their advice will result in a specific dollar or percentage increase in Medicare reimbursements, regardless of the prospective client’s particular circumstances. (The consultant’s fee often is based on a percentage of the increased reimbursement.)
- Consultants who promise to increase Medicare revenues for laboratory services by showing their clients how to disguise double billings and claims for medically unnecessary services.
- Reimbursement specialists who suggest that a client use inappropriate billing codes to elevate reimbursement and describe methods to avoid detection.
- Consultants who advise a client to modify or customize a routine medical supply in an insignificant manner solely to justify billing the item at a higher rate.
- Reimbursement specialists who suggest that a client bill for an expensive item with a high reimbursement rate when a less expensive item with a lower reimbursement rate actually was provided to the patient.
For a full copy of the advisory bulletin, go to www.os.dhhs.gov/progorg/oig/new.html.
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