A CMS Medlearn Matters memo titled Recovery Audit Contractor (RAC) Demonstration High-Risk Vulnerabilities for Physicians
, includes an area where anesthesiologists could be particularly vulnerable. The finding of concern is: Services billed with excessive units. Units billed exceeded the number of units per day based on the CPT code descriptor, reporting instructions in the CPT book, and/or other CMS local or national policy. The improper payments (prior to any appeal) comes to $6,635,558.
The ASA Relative Value Guide ® (RVG)
includes a base unit value for some non-anesthesia codes. We hear of instances where that base unit value is listed on claims submitted for these services. For example, the RVG notes that CPT® code 62311 (single shot lumbar epidural) has 8 base units. If that base unit value is listed in the field for “days or units,” Medicare may interpret this as billing for 8 injections which could attract unwanted attention from a Recovery Audit Contractor.