In response to the identification in the Office of Inspector General (OIG) 2010 and 2011 Work Plans of a rapid expansion of sleep study services, a Centers for Medicare & Medicaid Services (CMS) contractor has performed an analysis of billing practices for nine sleep study services. This analysis will be used to provide individual physicians with a Comparative Billing Report (CBR), which will address the services identified by the following CPT codes: 95805, 95806, 95807, 95808, 95810, 95811, G0398, G0399, and G0400.
It is the AASM’s understanding that each of the top 5,000 billers of these services nationally will receive a document that identifies his or her specific billing practices in comparison with his or her peers on a local and national basis. There will be a preliminary release of the comparative information to identified physicians in New Jersey in the next few days. Physicians in other states should expect to see a report by the end of the month or during the first week of June.
The stated purpose of the CBR is to “inform sleep study providers of billing data for selected services billed to Medicare and to help prevent improper payments.” The CBR is an educational tool that compares an individual physician’s provision of specific patient services. As noted in the report, “A statistically significant difference from your peers may be an indication of improper usage.” Please note that the emphasis (may be) is included in the report, and improper usage could be under- or over-use.
Answers to frequently asked questions about the CBR are available online. The AASM encourages each sleep center to develop and maintain a compliance program, and perform self audits to ensure that your center’s documentation supports the services it has billed.
