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Place of Service Audits

One item on the Office of Inspector General’s Work Plan for the past few years has been a concern about “Place of Service (POS) Errors”. Does the place of service on the claim form match the location where services were actually performed? Place of service errors affect physician reimbursement when the service provided has a site of service differential, is performed in either a hospital outpatient department or an ambulatory surgery center, and has a complementary facility fee.

Recently, First Coast Service Options, the Medicare contractor for Florida, reported the OIG’s audit results on claims from 2004 and 2005. They found services reported with place of service “office” yet there was also a claim filed for facility reimbursement (HOPD or ASC). Requests for review of these services have been made with instructions on how to return the overpaid dollars.

Although only a small amount for most practices, the review in Florida serves as a reminder to be diligent with the place of service on the claim form. With the change in ASC reimbursement last year, many practices shifted services (e.g., SLT/ALT, PI) from office-based to facility services. Beginning in January 2008, if your computer system defaulted to POS “office” for these and similar services, and they are now performed in the ASC, an overpayment exists.

Be sure to confirm accurate POS on claims, and correct payment amounts. The effort you make now may be very useful in the event of an OIG or local contractor review.

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