Recently the Office of the Inspector General (OIG) published findings of an audit conducted on a Florida-based independent diagnostic testing facility (IDTF), which found that the IDTF did not comply with Medicare billing requirements. The OIG audit report identifies a number of areas of non-compliance, the most frequent of which was a lack of required documentation supporting testing. This included lack of documentation of a face-to-face clinical evaluation, lack of physician’s orders, lack of interpretation report, or incomplete documentation of clinical evaluation.
Medicare’s documentation requirements for polysomnography are extensive. Within the OIG’s audit report, the OIG states, “Increased Medicare spending on polysomnography services; and growing concerns about fraud, waste, and abuse prompted us to conduct additional reviews.”
In light of this, the AASM encourages all members to review the documentation requirements outlined in your local Medicare coverage determinations (both for sleep testing and DME) to ensure compliance with all requirements. Local coverage determinations can be found on your Medicare Administrative Contractor website, or through the search feature on the Medicare Coverage Database.
