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Fraud and Abuse in

Medicare-What You Need

To Know

Presented to The American Academy of Professional Coders

Woodland Hills, California

Christopher Gagnon, Fraud Investigator/ September 19, 2013

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Agenda

SGS Overview

Fraud and Abuse –Definitions and Effects

SGS Investigations

Areas of Concern

What to Do If You Suspect Fraud

• Q & A

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SafeGuard Services, LLC Overview

SGS has served as the incumbent Program Safeguard Contractor (PSC) for:

Medicare-Medicaid for California since 2001

• Medicare Part B in California since 2002

• Durable Medical Equipment, Prosthetics, Orthotics, and Supplies

(DMEPOS) for Jurisdiction D encompassing seventeen states, including

California, Nevada, and Hawaii since March 2006

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• Zone Program Integrity Contractor (ZPIC) Zone 1 operations, integrating

Parts A, B, and DME, Hospice and Home Health claim types for fraud detection and prevention in California, Nevada, American Samoa, Guam,

Hawaii, the Northern Mariana Islands, Palau, Marshall Islands, and the

Federated States of Micronesia since December 2010

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CMS Definitions

Medicare Fraud

• When someone intentionally falsifies information or deceives Medicare.

Medicare Abuse

•When health care providers or suppliers don’t follow good medical practices, resulting in unnecessary costs to Medicare, improper payment, or services that aren't medically necessary.

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Effects Of Medicare Fraud & Abuse

• $60 Billion Estimated Annual Loss

Increased Costs of Healthcare – Throughout the Industry

Affects Everyone

Taxpayers

Beneficiaries

Providers / Suppliers

– Insurers

• Increased Scrutiny of All Claims

• Greater Burden for Beneficiaries & Providers

• Restrictions of Access to Care for Beneficiaries

• Unfair Competitive Advantage Over Legitimate Providers

• Damaged Reputation for Healthcare Industry

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SGS Investigations

What We Investigate

• Allegations of Fraud, Waste and Abuse related to Medicare-Enrolled

Providers/Suppliers

Who We Investigate

Hospitals, Home Health Agencies, Hospice Care (Part A)

Physicians, Clinics, Testing Facilities, Labs (Part B)

DME Suppliers (DME)

What We Do Not Investigate

Billing Errors

Disputes Over Quality Of Service Issues

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SGS Investigations

Where Do our Leads Come From?

External Referrals

• Fraud Prevention System (FPS)

• Medicare Administrative Contractor

• Beneficiaries

• Providers

• Centers for Medicare & Medicaid

Services

• Senior Medicare Patrol

• OIG Hotline Database

• Medi-Cal

• Law Enforcement

• Internally

• Data Team

• Investigators

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SGS Investigations

Schemes And Scams

Beneficiary Sharing

• Use of Cappers and other Illegal Marketing

• Soliciting, Offering or Receiving a Kickback, Bribe or Rebate

Provider/Beneficiary Identity Theft

Over Utilized Services

• Providing Unnecessary or Inappropriate Services

• Billing For Services Not Rendered

• Up-coding (Provider claim forms which have been altered to obtain a higher payment amount

DME’s-IDTF’S-Clinics-Physician Assistants

• Hit and Run

Non-existent Provider Office Locations (i.e., False Fronts, Store Fronts)

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Investigative Steps

Review of Claims History

Beneficiary Information

Provider Information

• Payment Information

Review of Multiple Data Bases

Review of Internal Reports/Data Analysis

Patients and Hours per day

Proximity to Office

Peer Comparisons

Review of Internet Sites

• Such as Medical Board

Obtain Provider Enrollment Applications

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Investigative Steps

• Prepayment Review May be Initiated

Obtain Sample of Claims Universe

Order and Review Medical Records

Post Payment Review by our Medical Review Team

Perform Beneficiary Validations and/or Interviews

Review Existing Complaints

Perform Provider Interviews

On-sites

Telephone

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Outcomes of Investigations

Any or All of the Following:

– Allegation Not Validated/Closed with No Actions Necessary

– Possible Administrative Actions

• Calculate Overpayment

Prepayment Review

Deactivation

Revocation

Payment Suspension

– Referral To Law Enforcement

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Examples

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Areas of Concern

From a Coders Perspective

• Egregious Up-coding

• Suites of Codes

• Unusual Codes for Specialty

• Consistent Use of Qualifying Modifiers

• Pressure from Provider to Change the Codes or Diagnoses

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What To Do If You Suspect Fraud or Abuse

1-800 Medicare (1-800-633-4227)

The OIG Hotline

• Phone: 800-409-9926

• The Office of Inspector General, HHS website https://forms.oig.hhs.gov/hotlineoperations

• Mail: Office of Inspector General

HOTLINE

P.O. Box 9778

Arlington, Virginia 22219

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In Closing

QUESTIONS?

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ZONE 1 CONTACT INFORMATION

Melisa Mulcahy

Program Director

916-317-2196 melisa.mulcahy@hp.com

Travis Moore

Acting Manager-Task Order 1

(213) 553-5237 travism@hp.com

Beth Romig

Benefit Integrity Manager

(530) 896-7053

Beth.romig@hp.com

Mike Devlin

Manager-Task Order 2

(530) 896-7054

Mike.devlin@hp.com

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© Copyright 2013 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.

Thank you

© Copyright 2013 Hewlett-Packard Development Company, L.P. The information contained herein is subject to change without notice.

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