People I know like to criticize my driving. I drive fast, I drive aggressively and I make no apologies for it. The sooner that the rest of the world learns to stay out of my way, the better.

When I get into a car, I know exactly where I’m going. I don’t own a GPS device. I map it out before I leave the house, and arrive on time. If you have no idea where you’re headed or how to get there, what are you doing in a large, multi-ton piece of metal racing down the highway? At this point, you are no longer a responsible driver. You have now become a potential battering ram, and if I happen to be on the road at the same time, I shall be more than happy to give you a stark visual reminder of what you can do with yourself and your car.

Thanks to technology, we have a number of ways to find our exact location on the planet at any time of the day or night. We can now also share that with friends and acquaintances thanks to cell phone applications. As an example, I type this from my current location of Latitude 43.0582351° North and Longitude 88.0474888° West.

Apparently, determining one’s whereabouts are not quite so easy for physicians.

As part of the automated review process, the RAC contractors have been comparing place of service codes on physician claims and finding that the same beneficiaries are incurring hospital outpatient services on the same date. This leads to a recoupment of the difference between reimbursement of a claim at the higher non-facility rate and the facility rate.

The results of an OIG review of 100 non-facility services from 2007 was released on July 28, 2010 by CMS. The services were selected from a universe of claims where a correlating facility charge existed for the same patient on the same date of service. Of the services reviewed, only 10 were found to have the correct place of service on the claim. The OIG estimated from this review that CMS overpaid physician claims to the tune of $13.8 million. As a result of this review, CMS is referring over 484,000 physician claims of this type to the RACs and other recovery entities to pursue overpayments.  

This appears to be a fairly easy fix. Before performing services in a place of service, ask yourself three questions: where am I, will a facility billing be generated for the services I am about to perform and (if you don’t know the answer to number two) am I responsible for the expense of this space that I currently occupy. Are we in an office or an independent or hospital-owned surgical suite? It’s not that difficult when broken down to the bare minimum.

I’ll equate this to driving. In the same way that you should know where you’re going in your car, if you don’t know where you are and what your costs are for performing the services you are about to deliver, why are you examining me?