The Office of Inspector General (OIG) is turning a keen eye toward lower extremity revascularization procedures this year. That’s right, in the world of interventional radiology, it’s audit season—like tax season but with more leg work (literally).

Why Legs Are Getting Extra Attention

Let’s talk legs. Not just any legs, but legs that have seen better days. The OIG is acting under the suspicion that lower extremity interventional revascularization procedures, such as angioplasty, stenting, and atherectomy are being performed without adequate medical necessity. The OIG isn’t just being nosy – they’re checking to ensure every procedure is absolutely necessary, asking questions like, “Did you really try walking it off?” before letting doctors go balloon-popping in someone’s arteries.

The Goldilocks Rule of Coding… and Documentation

Coding is always a balance between coding too much and coding too little. I like to call this the Goldilocks Rule of Coding where we code “just right” – that is, capturing all the diagnoses and services for which the provider is due while avoiding upcoding, which can land a provider in compliance hot water. But coders are only as good as the documentation from which they are coding, so a focus on shoring up provider documentation is key.

What is the OIG Looking For?

The OIG’s investigation is expected to examine whether hospitals have been compliant with coding rules, focusing on whether they are upcoding or undercoding. This includes scrutiny of whether these procedures are medically necessary. Chart reviews will dig into the documentation to determine if providers “showed their work” when it comes to documenting justification for the procedures, including conservative alternatives. But you can bet that if they see additional opportunities to take back monies for the Medicare program, they will seize the day.

Common Coding Missteps in the World of Vascular Interventional Radiology

At the facility level, errors in coding and charging for interventional radiology procedures are often the result of a siloed coding approach where the procedures are coded partially by a coder and partially through charges in the chargemaster. Other process issues that could lead to incorrect coding and billing include hardcoding these procedures through the chargemaster without oversight by a coding professional. The rules for coding these procedures are complex and require advanced training, which can be costly, leading some to devalue the return on investment, particularly when process improvement identifies that the facility is overcoding. With this spotlight by the OIG, hospitals and physicians might face fines or other penalties for failing to document and code the procedures according to AMA and CMS requirements.

What Can You Do to Prepare?

As the investigation unfolds, healthcare providers specializing in interventional radiology will need to scrutinize their coding practices and ensure they adhere to the highest standards of accuracy. You can prepare now by pushing for documentation improvement, more stringent coding education, and process oversight and improvement. Need a partner? Haugen Academy is here to help. With our blend of online and mentor-guided learning and expert consulting services, we’ll get your team coding compliantly and accurately in no time!