The newsletter is no longer being published. Archived newsletters remain on the website for historical reference.

DISCLAIMER: The Compliance Matters Newsletter is prepared by the Office of Physician Billing Compliance (OPBC) and is published only for Washington University School of Medicine faculty and staff.  The OPBC strives to provide accurate, timely, and relevant information at the time of publishing.  Regulations and requirements, however, can change over time and the reader must take into consideration the publishing date for each Compliance Matters Newsletter when reading the content and determining timeliness of the information therein.

Although Compliance Matters Newsletters may include links providing direct access to other internet resources, including non-governmental web sites, OPBC has not participated in the development of those sites and is not responsible for the accuracy or content of their information nor does OPBC endorse or recommend products and services on those sites.

Compliance Matters – September 2014

  • NPP assistant at surgery and global surgery package
  • Distinct procedural services modifiers
  • Medically unlikely edits and bilateral procedures

Compliance Matters – December 2013

  • Defining “immediately available”
  • Split/shared service documentation
  • Medical necessity for appropriate billing of e/m services
  • Mandatory reporting of 8-digit clinical trial number
  • Quick Blips: Appeals based on sub specialty, CLIA-waived tests, Documentation of 3  chronic or inactive conditions, Modifier 62

Compliance Matters – March 2013

  •  Billing critical care services
  • Mid Level Providers and Appropriate Billing
  • Teaching Physician Billing Rules

Compliance Matters – May 2012

  • Use of Co-signature to Support “In-the Suite” Presence for “Incident to” Services
  • CMS’ Instruction for Reporting Correct Place of Service
  • Finalized Rule for Ordering and/or Referring Providers Includes Instructions for Interns, Residents & Fellows in “Approved Programs”

Compliance Matters – April 2010

  • CMS hot topic – Provider signatures
  • Medicare No Longer Recognizing CPT Consultation Codes 99241 – 99255
  • Updates to ABN Modifiers
  • POS & DOS for Diagnostic Tests
  • New, Improved, Streamlined Medicare Appeals Form
  • Q&A: Sharp debridement vs selective debridement,

Compliance Matters – June 2009

  • Medicare’s Comprehensive Error Rate Testing (CERT) Program – What It Is & Its Relevance to Physicians and Practices
  • TP presence and documentation requirements table
  • Q&A: Use of scribes by TP; Medical student documentation

Compliance Matters – June 2007

  • Revisions to the Medicare Claims Processing Manual Regarding Discarded Drugs & Biologicals
  • National Correct Coding Initiative
  • Services of Physician Assistants
  • Q&A: Removal of impacted cerumen

Compliance Matters – March 2007

  • Missouri Medicaid to Follow National Correct Coding Guidelines
  • Processing All Diagnosis Codes Reported on Claims
  • Medically Unlikely Edits (MUEs)
  • Q&A: TP documentation requirements for endoscopies; Overlapping surgeries in ER

Compliance Matters – November 2006

  • EMR Impact on Physician Reimbursement
  • Addenda Guidelines
  • Missouri Medicaid Requires Documentation of Time

Compliance Matters – May 2006

  • Clinical Trial Billing – Summing It All Up
  • Q&A: Incident-to services; Modifier 51

Compliance Matters – May 2006 Clinical Trials Billing

Compliance Matters – February 2006

  • Billing for Medical Device Clinical Trials
  • Q&A: Macro’s in an EMR; GR modifier

Compliance Matters – November 2005

  • An Introduction to Clinical Trial Billing
  • Missouri Medicaid Allows IDTFs to Provide Services
  • Q&A: Does HIPAA mandate that all payers follow the coding guidelines for each of the medical code sets?

Compliance Matters – August 2005

  • Q&A: When to Append Modifier 57

Compliance Matters – May 2005

  • Incident-to Revisted
  • When are Fellow Service Billable
  • Welcome to Medicare Physical and the Primary Care Exception
  • Q&A: Is it acceptable to report an initial hospital visit more than 24 hours after admission?

Compliance Matters – February 2005

  • Q&A: HCPCS II code G0350; Time required for CPT code 96412

Compliance Matters – November 2004

  • A Review of the Teaching Physician Supervision Guidelines for Procedures
  • Q&A:  How to bill for multidose vial; What date to put on lab tests; Reporting 95180

Compliance Matters – August 2004

  • What You Should Know about Prepay Reviews
  • Pay Attention to AdvanceMed Letters
  • Q&A: Billing for bronchoscopes used to verify placement and/or reposition of ETT

Compliance Matters – April 2004

  • “New problem” Under Incident-to Guidelines Clarified
  • Where to Find RVU Information

Compliance Matters – February 2004

  • Watch Out for Modifier 25
  • Conscious Sedation
  • Q&A:  What is a confirmatory consultation; Compliance education requirements

Compliance Matters – December 2003

  • Q&A: When should the unlisted CPT code be used

Compliance Matters – October 2003

  • How to Report Split/Shared Services
  • Understanding the Medicare Appeals Process
  • The Issues with Critical Care
  • Which code get the 59 modifier

Compliance Matters – August 2003

  • ADR’s are not Denials
  • Medicare Policy Decisions – You Do Have A Voice
  • Q&A: Transcription tag lines; Billing Medicare for drug waste: Significance of status B indicator

Compliance Matters – June 2003

  • Introduction to Fraud & Abuse
  • Supervision Requirements for Diagnostic Tests
  • Injectable Drug Billing Clarified
  • Q&A: What’s the correct way to bill for compounded drugs; Checking for orders when auditing diagnostic tests

Compliance Matters – April 2003

  • Q&A: Reference to resident; Where to find reliable references

Compliance Matters – February 2003

  • Diagnosis Coding : Why Accuracy Counts
  • Searching the OIG Exclusion Database
  • Q&A: Initial hospital billed as subsequent; Documentation for counseling/ coordination of care; Coding a “history of” diagnosis

Compliance Matters – October 2002

  • The ABCs of ABNs
  • CCI: What is it and why should you care
  • Reference to Resident Revisted
  • Q&A: When to report 36410 (venipuncture); 2-4 organ systems versus 5-7

Compliance Matters – August 2002

  • Consulations – Billing and Documentation Guide
  • Fee Tickets can get you in Trouble
  • Concurrent Care
  • Prolonged Services (99354-99357)
  • Q&A: Can obtaining blood specimen through implanted venous access device be billed

Compliance Matters – June 2002

  •  Incident-to guidelines
  • Venipuncture documentation
  • Q&A: Difference between new and established patient; Billing for inpatient admission when patient converts from observation to inpatient