HEALTH INSURANCE FRAUD GHANA’S PERSPECTIVE NHIS@10 Conference Dr. Lydia Dsane-Selby Director, Claims 5th November 2013 Outline Definition Motivators Types of Fraud & Abuse Prevention/Mitigation Pre-payment methods Post –payment methods The Way Forward Definition FRAUD: • The crime of deceiving somebody in order to get money or goods illegally. • Intentional deception perpetrated for profit or to gain some unfair or dishonest advantage Health Insurance Fraud Health insurance fraud is an intentional act of deceiving, concealing, or misrepresenting information that results in health care benefits being paid to an individual or group. Fraud can be committed by both a member and a provider. Motivators - Providers Wide range of potential medical conditions and treatments to choose from Fidelity to patients Exploitation of loopholes in the provider payment system Inadequate fraud prevention and detection amongst insurers Often seen as a “victimless” crime Limited sanctions and legal deterrents against public sector facilities Motivators - Members Misconceptions about insurance – victimless crime, insurers have lots of money Mutually beneficial to parties involved Exploitation of loopholes Financial gain Limited legal deterrents or sanctions Types of Fraud/Abuse - Providers Billing for services not rendered Up-coding of services Double billing/Duplicate claims Misrepresentation of diagnosis Unbundling of services Unnecessary services Inappropriate referral for financial gain Insertion/Substitution of medicines Unauthorised co-payments Types of Fraud/Abuse - Members Impersonation – a non-member using a member’s identity Ganging – all the family using one member’s card Provider shopping Illegal cash exchange for prescriptions Frivolous use of services – drugs for sale Ways to prevent/mitigate abuse Policy methods – through appropriate payment mechanisms Each payment method has its advantages in tackling certain types of abuse Pre-payment methods – effective claims processing Membership Treatment protocols Electronic vetting business rules Post-payment methods Data analysis Clinical Audit & claims verification Claims Processing Eligibility & Membership E-Vetting & E-Adjudication Provider Payment Paper Claims G-DRG E-Claims ICD-10 Treatment Codes Process, Business Rules Based Engine !! Statistical Data 22 Pre-Payment Methods Claims management – Electronic & Manual Biometric authentication at provider site – eligibility & membership – generate claims check code Member unique ID number checked against membership database when claims submitted Alert for any claims using the same unique ID number within the last month at any provider Check appropriateness of diagnosis against age and gender Check match between diagnosis and treatment Check that agreed tariffs for medicines and services have been used Claims Adjustments CPC v District Post-Payment Methods Data Analysis Top 20 in-patient DRG’s for each specialty Top 50 medicines diagnosed – by volume and by value Service utilisation – OPD and IPD Cost per claim for different provider types Monthly value of claims per provider type per district Month on month value of claims for each provider Post-Payment Methods Claims verification & Clinical Audit Verify the attendance at the provider site Verify the services given Verify the medicines prescribed and dispensed Contact members to confirm attendance, services & medicines given Assess the quality of care Clinical Audit - Background & progress • September 2009 – Claims & Clinical Audit Division created • January 2010 - Clinical audits commenced formally • March 2010 – Separation of Clinical Audit Division • June 2010 – Clinical Audit Manual developed • December 2010 – Audit tools developed • Biannual meeting with stakeholders to refine process & discuss findings • May 2013 – Clinical Audit & Accreditation merged Clinical Audit Process • • • • • • • • • • • • Multi-disciplinary teams drawn from private & public sector. Selection of auditee providers based on risk profile Auditee providers selected from entire range of service provision Prior notification of audit visits to ensure acceptance and results Prior notification of clients whose folders have been selected for audit Clients’ medical record/folders examined for: Linkage between treatment and diagnoses/adherence to treatment guidelines Accuracy of claims based on medicine dosage, strengths, and quantities Appropriateness of tariffs applied for services provided Evidence of co-payment Exit conferences with management of provider facilities to discuss findings. Furnishing of providers with draft report (including discussed findings, recommendations and way forward Opportunity for providers to dispute of findings and recommendations Dispute resolution if required Final report sent to providers (include claims deduction, dis-accreditation, recommendation on quality improvement) with copies to umbrella organisations and associations Follow-up on Recommendations through NHIA Regional Offices Audited v Unaudited facilities Category of findings ERRORS ABUSE PROVIDERS SCHEMES FRAUD CLINICAL AUDIT FINDINGS QUALITY OF CARE Examples of fraud • Public & Private facilities with same doctor where 1524 patients visited exactly one month apart NAME DATE (PUBLIC) G-DRG DATE (PRIVATE) G-DRG B. A. 18/10/2012 DENT18A 18/11/2012 (Sunday) DENT18A S. M. 24/4/2012 DENT19A 24/5/2012 DENT12A G. B. 13/4/2012 DENT19A 13/5/2012 (Sunday) DENT02A N. A. 15/3/2012 DENTO2A 15/4/2012 DENTO2A DENT02A = Surgical removal of tooth DENT12A= Sialodectomy DENT18A=Partial resection of the facial bones DENT19A= Total resection of the facial bones & soft tissues Examples of fraud • Spurious claims – Facility puts in claims for deliveries for patients who attended Antenatal clinic but delivered elsewhere • Recycling of claims from previous months to boost numbers • Recycling of patient details between facilities The Way forward Whistleblowers Clean claims Encourage whistleblowers and protect them by legislation Early reimbursement for providers with clean claims. % tariff increase for adherence to treatment protocols % tariff increase Training of health insurance staff in fraud detection Advocacy on impact Increased advocacy and sensitisation on the impact of fraud and abuse on the health insurance system The Way forward Legislation Financial penalties Disaccreditation/ loss of license Name and Shame Pass specific health insurance fraud laws making it a criminal offence e.g. USA Health Insurance Portability and Accountability of 1996 (HIPAA) Financial penalties above repayment of fraudulent payments Health care provider should lose its license with the regulatory bodies as well as disaccreditation by the insurer Public gazetting of fraud and abuse cases CONCLUSION • Health Insurance fraud is a global phenomenon • It cannot be eliminated entirely but can be minimised • Methods to prevent fraud is insurance scheme and country specific although there are general measures that can apply to all • There will always be loopholes in the medical scheme. • Each time a loophole is closed, another is found. • Insurers need to work with providers and members if the prevention methods are to be successful. Thank you Merci Gracias ありがとう 감사합니다 ขอบคุณ