OIG Recommends PMD Claims without a Corresponding G Code be Scrutinized
The OIG conducted a study on the use of the optional G code that was established in 2005 to provide additional reimbursement to physicians for documenting a face-to-face examination required for PMDs.
In a January 2015 OIG report, they found for PMD claims with corresponding G-code claims, Medicare paid the PMD claims in accordance with federal requirements for face-to-face examinations of beneficiaries. For PMD claims without corresponding G-code claims, Medicare did not always pay the PMD claims in accordance with federal requirements for face-to-face examinations.
The OIG concluded that there is a correlation in the quality of the face-to-face documentation when the physician billed the G code. Their findings show that when the physician billed the G code, they appeared to have a better understanding of the requirements of the face-to-face, and provided a more comprehensive examination compared to when the physician did not bill the G code. The OIG recommended to CMS that there be more scrutiny on PMD claims when the G code is not billed. A claim will not simply be denied because the physician didn’t bill the G code, however those claims may receive a higher level of scrutiny to ensure the face-to-face exam meets the documentation requirements of a face-to-face.
Providers should ensure (pre-delivery) that the face-to-face examination notes meet the face-to-face requirements. It they do, you shouldn’t be worried about the additional scrutiny if it should come.
The take-away from this is to continue to educate physicians on the face-to-face requirements and the use of the G code. When contractors find the G code, they may be less likely to scrutinize the face-to- face. As of today, DME contractors are not required to find the G code, however, the OIG has brought this to CMS' attention.
Complete OIG Article.