Johns Hopkins Gazette: November 18, 1996 Form

Review At SOM

Federal agency may look
at faculty physician's
billing practices.

The federal government's nationwide audit of Medicare billing by faculty physicians at teaching hospitals may now include a review at Johns Hopkins.

The university has received a Department of Health and Human Services request for background information. HHS said it will use that information to select physician group practices for a review, including an audit of patient records and interviews of some doctors and staff. It set no date for on-site work to begin.

HHS announced in June, after reaching settlements on alleged overbillings by faculty physicians at two Philadelphia universities, that it was launching audits at academic medical centers across the country.

The government is looking primarily at whether there is documentation in patient records that teaching physicians, who train and supervise medical residents, were directly involved in the care of Medicare patients for whom they submitted bills. The audit will also consider whether charges billed to Medicare patients--patients covered by the government's health insurance plan for senior citizens--were at appropriate levels.

The audits are not focusing on the quality of care provided to Medicare patients.

In a letter to School of Medicine faculty last week, President William R. Brody and interim Dean Edward D. Miller Jr. said the university will cooperate fully with the audit and will reimburse the government for any overpayments discovered.

"We want to express our confidence that members of the faculty have made a good faith effort to comply with the complex, vague and ambiguous documentation requirements attendant to Medicare billing," Brody and Miller wrote. "We wish to assure you that you will have our full support in meeting challenges posed by the audit."

More than two dozen academic medical centers, including, recently, the University of Maryland at Baltimore, have been notified of HHS audits. The Association of American Medical Colleges reports that, in general, the government has selected a random sample of 100 to 200 inpatient and outpatient Medicare records from 1994. The results are then extrapolated over the six-year period, 1990 through 1995, that is subject to the audit.

The problem, the AAMC reports, is that the government auditors may be applying retroactively Medicare billing regulations that just went into effect in July 1996. The Health Care Financing Administration, the government agency that runs Medicare, readily admits that there was considerable ambiguity and confusion about the billing rules before last July, the AAMC said.

Further, the association said, the nearly three dozen Medicare claims processors employed by the government around the country interpreted and enforced the rules differently. That effectively resulted in different standards around the country for documentation of a teaching physician's physical presence when a resident was caring for a patient.

Brody and Miller, in their letter, advised faculty members that they have the right to have a university attorney present at any interview or meeting requested by an auditor. The same right exists for any staff member. They may request that the interview be scheduled after the university's lawyers are contacted, the letter said.

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