By Francie Fernald - February 9, 2012

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Physicians received two important notices recently, one from CMS issued Feb. 3, and the other from the HHS Office of Inspector General, issued Feb. 8.

The CMS notice is Trans. 2407, which takes effect on April 1. It establishes a new national policy for assignment of place of service (POS) codes. In essence, the POS is where the patient receives the face-to-face service. CMS issued this policy because OIG has consistently found that physicians report the POS incorrectly, often reporting an office-based service when the service actually was performed in a hospital outpatient department or an ASC. And this means the physician was overpaid for the service, which creates a compliance problem.

The other notice is a fraud alert from OIG reminding physicians that they could be liable for false claims allegations if they assign their provider number for payment purposes and the assignee submits inaccurate claims. The alert describes settlements with eight physicians who did not monitor the entity billing for their services, and the services billed under the physicians’ provider numbers were not performed or not performed as billed. OIG encourages “heightened scrutiny” when assigning the right to Medicare payments and reminds physicians that once they have assigned their right to bill Medicare, they have the right to access the entity’s billing information regarding services billed under their own provider number.

Do physicians receive the information such as the notices discussed above in a timely manner? Does this depend on practice size? What role do hospital compliance officers play in keeping physicians informed of important changes and developments?