In many ways, compliance officers are the eyes in the sky of healthcare organizations. We prevent and mitigate non-compliance, and for this reason, we need to be vigilant and wide-awake, especially when it comes to healthcare providers offering sleep study services to their patients.
Recently, the OIG performed three major audits of sleep studies services at The University of Michigan, Peninsula Regional Medical Center in Maryland, and North Mississippi Medical Center.
The OIG uncovered non-compliance, which is noteworthy in and of itself. But the reasons for non-compliance are even more interesting (and important for keeping our organizations compliant). The OIG found overpayments linked to all kinds of things like improper billing due to improper coding or because the service was never performed, but the record wasn’t correctly updated.
What’s the difference between 4 and 6 hours of sleep? When it comes to a sleep study, everything. Less than six hours requires a –52 modifier, and without it, there are overpayments galore. And we all know what happens when the OIG uncovers overpayments.
It’s clear from these audits that the OIG wants polysomnography studies (sleep studies) to be billed in a compliant manner. So if your organization performs these services, it’s crucial to proactively audit these types of claims and watch out for the non-compliant types of bills identified by the OIG in these three audits. For example, inappropriate coding (–52 is where it’s at!), lack of medical evidence that supports the need for tests, incomplete documentation, and so much more!