Today, Safequard Services — a Centers for Medicare and Medicaid Services (CMS) contractor — is scheduled to release its first national Comparative Billing Report on Advanced Diagnostic Imaging. The CBR will draw from Medicare final paid claims data with 2010 service dates to create tables and graphs showing how a provider's billing and payment patterns compare to those of their peers in their state and across the nation.
The four-page reports are confidential and available only to the providers who receive them. A PDF sample is posted online.
On both the CMS and Safeguard websites, there are written assurances that the CBRs are intended only to help diagnostic imaging providers spot problems with their billing patterns. They are not intended to be a prelude to a billing audit or any punitive actions.
However, the health care services selected for the initial CBRs include many that CMS has long targeted for issues with fraud and abuse. Besides advanced diagnostic imaging, they include durable medical equipment, sleep medicine, chiropractic services and physical therapy services.
If you receive one of these reports, it is wise to pay close attention says Mark F. Weiss of Los Angeles-based Advisory Law Group, a specialist in legal and business concerns for health care providers.
"The notion behind CBRs is to provide educational guidance in respect of coding and billing practices, not, purportedly, to be punitive," Weiss says. "Of course, the government's great at capturing information and where it will end up is anyone's guess."
Should you receive one of these reports indicating that your billing pattern varies from that of other diagnostic imaging providers, Weiss recommends taking the following three actions:
- Study the report and discuss it not only among group leadership but with the billing manager, whether in-house or with a billing service. There may well be a valid and benign reason why your data varies from the peer group.
- If there is not a valid reason for the variance, then group leaders and their billing managers should investigate whether they have properly coded and, if necessary, take corrective action in respect of their claims.
- Even though there is purportedly not a punitive aspect to the CBR process, I would advise radiologists that if there is a significant variance between their coding practices and that of the peer group, they should consider themselves as potential targets for audits and investigations and take appropriate action.