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Medical Coding News Archives

Report Unearths ED Errors When Reporting Imaging Services

May 18, 2011:

Nannette Orme, CPC, CCS-P, CPMA, CEMC; Clinical/Technical Editor

A report released by the Office of Inspector General (OIG) found significant errors in the reporting of imaging services performed on Medicare beneficiaries in the emergency department during 2008. These failures to meet guidelines for reimbursement are thought to persist today.

One of the first failings noted was the lack of a physician’s order for imaging services in the patient record. For an ancillary service to be covered, there must be a physician order supporting that service in the patient record. However in the OIG report, 12 percent of computerized tomography (CT) and magnetic resonance imaging (MRI) exams and 8.6 percent of other imaging services did not have such an order in the patient chart, accounting for $23.5 million in overpayments.

Documentation to support the interpretation, or reading, of the imaging study was missing for 12 percent of the CT and MRI exams and 8.2 percent of other imaging services. The OIG reports that this accounts for $24.4 million in overpayments.

The OIG report also noted that between 69 percent and 71 percent of all imaging and CT/MRI reports did not follow the documentation guidelines of the American College of Radiology (ACR).

CMS agrees with the following OIG recommendations:

  • Providers should be educated regarding required documentation that must be maintained to support medical necessity for imaging services
  • Providers will be notified regarding erroneous payments and the actions to be taken

The OIG report also noted that a high number of imaging studies were not interpreted until after the beneficiary had left the emergency department. Although the agency does not call this an error in reimbursement, it suggests that the imaging study may not have been appropriately used for treating the beneficiary. When interpretations or readings are submitted from both the emergency department physician and the staff radiologist, only one may be paid for. In this circumstance the Medicare contractors may pay only for the interpretation that directly related to the treatment of the beneficiary. In these circumstances the OIG recommended that the interpretation and report be completed while the beneficiary is still in the emergency department.

The agency recommended a single policy for contemporaneous interpretation and reading of imaging studies and for situations in which a contemporaneous reading is not required, but CMS did not concur with this recommendation.


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