The Department of Health and Human Services Office of the Inspector General (OIG) in late June issued an audit report that reviews claims billed by independent diagnostic testing facilities (IDTF) for services provided to Medicare beneficiaries during 2001. As many sleep centers are IDTFs, this information is particularly important to members.
The OIG audited a sample of claims submitted by IDTFs to Medicare for beneficiaries with 100 or fewer services to determine whether:
(1) Services that IDTFs provided to Medicare beneficiaries were (i) reasonable and necessary; (ii) ordered by a physician; and (iii) sufficiently documented in accordance with Federal laws, regulations and guidelines
(2) IDTFs operated in accordance with their initial enrollment applications and subsequent updates filed with carriers
Based on the findings in the audit, OIG recommended that CMS implement site visits to audit enrollment compliance and to pursue potential recovery of improper payments related to IDTF services, which exceed $71.5 million.
CMS may step up its enforcement activities with regards to IDTF services. It is recommended that IDTF operators ensure their center has an effective compliance plan to ensure medical records comply with billing requirements, medical necessity is documented in the patient record and a physician’s order is on file for every procedure. Additionally, an IDTF should ensure it is operated in compliance with its enrollment application, including operational changes.