EDX Fraud & Abuse

Report
The Many and Varied Types
of
Fraud and Abuse
in
Electrodiagnostic Medicine
Peter A. Grant, M.D.
November 15th, 2014
A.A.P.M.&R. – San Diego
.
Peter A. Grant, M.D.
Past President – American Association of
Neuromuscular & Electrodiagnostic Medicine
Diplomate - American Board of Physical
Medicine & Rehabilitation
Diplomate – American Board of
Electrodiagnostic Medicine
Specialist in EDX Fraud & Abuse (15 years)
AANEM Accredited EDX Laboratory
DISCLAIMER
Please note that any and all
comments made in this
lecture are mine and NOT
the AAPM&R or the AANEM
or any other organization.
Outline of Presentation
Why EDX Fraud & Abuse?
What constitutes “Quality EDX”
Types of EDX Fraud & Abuse
Addressing EDX Fraud & Abuse
Resources
EDX Laboratory Accreditation
Fraud Trends & “Red Flags”
Reimbursement Cuts & EDX
Fraud and Abuse
WHAT’S THE CONNECTION?
“These cuts were, most definitely, due to the
increased utilization of the NCS codes”
(Jonathan Blum – Deputy Director CMS)
So…. The Reimbursement Cuts were a direct
response to Fraud & Abuse in EDX.
Types of EDX Fraud & Abuse
LEGAL MEASURE OF QUALITY
Community, regional, or national standard
of care for EDX evaluations.
Current & Historical EDX practices in your
community.
What AANEM (with endorsement of AAN
and AAPM&R) promotes and publishes as
standards for EDX exams to be appropriate,
accurate, and necessary.
Types of EDX Fraud & Abuse
THE MANY FACES OF POOR QUALITY
Inaccurate Diagnosis
Wrong Diagnosis
Missed Diagnosis
Overdiagnosis
Excessive, Inapproriate, or Insufficient
Testing
Excessive or Inappropriate Charges
Types of EDX Fraud & Abuse
Common to All Abusive & Fraudulent EDX
Emphasis is on $$$
and Not on
Quality
EDX Studies/Patient Care
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
MOBILE
DIAGNOSTIC
LABORATORIES
A true case …
Husband & Wife involved in MVA
Referred by chiropractor to have EDX
Studies performed in chiropractors
office
Chiropractor bills/collects $
Mobile Diagnostic Lab (MDL)
bills/collects $ for the husband and $
for the wife
Case # 1
 All diagnoses made by MDL later found
to be erroneous
 Poor Quality / Abuses
1. Excessive Charges - $14K & $12K
2. Excessive, Unnecessary, &
Inappropriate Testing - (> 20 nerves
tested in each – incl Bilateral Phrenics!)
3. Inaccurate Diagnoses
Another true case…
47 yr old man with R leg weakness
Primary care MD orders EDX
MDL comes into his office to perform
EDX study (NCS Only)
Patient dxd with “Peroneal
mononeuropathy at fibular head
involving only motor fibers” (??)
Repeat EDX study 3 weeks later (by
ABEM EDX Consultant) found classic
ALS (Hx, PE, & EDX)
Case # 2
 Patient treated with Bob Miller at
ALS clinic in San Francisco before
he died.
 (MDL billed patient >$7,000!!!)
 Poor Quality / Abuses
1. Inaccurate Diagnosis
2. Excessive Charges
3. Excessive, Unnecessary, &
Inappropriate Testing
Mobile Diagnostic
Laboratories
Basics
of
How They Work
Mobile Dx Labs
Basics of How They Work
Marketed to Potential Referral Providers
“Why send EDX studies out when you can
profit by having EDX studies performed in
your own office?”
Typical Target Providers
 Family Physicians
 Internists
 Other MDs/DOs/FNPs/PAs
Chiropractors
Mobile Dx Labs
Basics of How They Work
Provider Makes Referral
MVA, MC, Privates all billed now
Technician Sent to Providers
Office
I have seen them sent >2000
miles!
Mobile Dx Labs
Basics of How They Work
NCS Exam Performed
Most (if not all) Motor Studies
Most (if not all) Sensory Studies
Most F-waves & H-reflexes
Sometimes SSEPs and DSEPs
Sometimes MS Ultrasound performed
No EMG performed (? Surface EMG)
No good Hx or PE performed!!!
Mobile Dx Labs
Basics of How They Work
Provider bills “Technical Component”
MD at MDL “homebase” interprets NCSs
MD at MDL “homebase” charges
“Professional Component”
MD at MDL “homebase” makes
diagnoses and sends report to provider
Mobile Dx Labs
Basics of How They Work
“New & Improved” (Mutated) MDLs
Changes to address “red flags”
Marketed to potential NCS Interpreters
MDL enlists physicians to interpret NCS for
a set fee
Fee is per each nerve or per whole NCS
Mobile Dx Labs
Basics of How They Work
“New & Improved” (Mutated) MDLs
MDL #2 otherwise looks and acts like #1
MDL markets to referring providers
MDL sends out EDX technician to perform
No good Hx or PE performed
Excessive number of nerves is norm
Features Common
to
Mobile Diagnostic
EDX Labs
Features Common to
Mobile Diagnostic Labs
“Shot Gun” excessive # of NCSs
Templated – same nerves every study
Technician performs studies
Poor quality NCSs
No good HX / PE to guide exam
Inaccurate diagnoses
Features Common to
Mobile Diagnostic Labs
Poor Quality NCSs
Interference very common
Inaccurate marker placement
Inappropriate electrode placement
(e.g. not on motor point)
Inappropriate stimulation – too low or
too high (with volume conduction).
All lead to inaccurate and unreliable results!
Features Common to
Mobile Diagnostic Labs
Inaccurate Dxs
 Often dx radiculopathy based on
F-waves (no EMG)
 Often see multiple diagnoses
(multilevel/bilateral radiculopathies)
 Often see diagnoses that make no
neurophysiologic sense
Features Common to
Mobile Diagnostic Labs
Emphasis on profits - not on accuracy
MDL “home base” is usually far away
Previously was mainly MVA patients
Now billing more private carriers & even
Medicare/Tricare (FBI/US AG)
AMA-CPT Coding Book
To address Mobile Dx Labs
Revised in 2013
“Waveforms must be reviewed on site
in real time, and the technique must be
adjusted, as appropriate, as the test
proceeds…”
“Reports must be prepared on site by
the examiner…”
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
HAND-HELD
DEVICES
Hand-held Devices
Deleted 27 slides from presentation
Bigger issue 2006 – 2010.
AANEM/AAPM&R/AAN addressed
As of 1/1/10 given CPT code 95905
Pays much less than standard NCSs
Can be billed once per limb only
Hand-held Devices
CONTINUED PROBLEMS
Often don’t use new CPT 95905
Use HHD to substantiate “need” for
surgery, injection, or other Rx ($$)
Still in wrong hands – not in offices of
those that can best dx appropriately
Most diagnoses are missed (my slides)
Poorly diagnoses CTS / GPN / UN@E
Hand-held Devices
CONTINUED PROBLEMS
No info re: amp / dur / conduction block
Cannot assess prognosis
Diagnose radiculopathies without EMG!
“Shotgun” - excessive number of NCSs
Preset battery of NCSs – cannot change
No individual results until test completed
Hand-held Devices
CONTINUED PROBLEMS
Cannot change focus during testing
Company promotes serial “monitoring”
Slick marketing dupes providers
Company says no diagnoses – “only
interpretations” therefore no liability
Must tell providers they are legally
liable when they sign bottom line of
report
Hand-held Devices
TESTING FOR CARPAL TUNNEL SYNDROME
Median Sensory to 3rd/Long ONLY
No comparison Med vs. Rad or Med vs. Uln
No Med vs Uln Motor
Abnormal by absolute values only
No ability to assess Conduction Block
No EMG
How SENSITIVE would I be with all of
these limitations !?!?!?
Hand-held Devices
PROMOTES UNNECESSARY TESTING
For “non-radicular” back pain one
company recommends:
Bilateral Peroneal Motors
Bilateral Peroneal F-Waves
Bilateral Tibial Motors
Bilateral Tibial F-Waves
Left or Right Sural Sensory
9 NCSs FOR NON-RADICULAR
LOW BACK PAIN!!
Hand-held Devices
NOT USED AS INTENDED???
Comments from CEO of HHD company:
Re: their HHD being used by surgeons to justify
CTDs - “I would never argue that this
technology should be used for surgical decision
making.”
Re: liability issue - “We are an equipment
manufacturer - we have no (medical) liability.”
“Complicated and involved cases should be
referred to specialty trained Neurologists and
Physiatrists”.
Hand-held Devices
NEW DEVICE
Assessment of single or bilateral surals
Gives velocity and amplitude
Don’t position correctly can get smaller
amplitude (and slowed velocity)
Make diagnosis based on only this data!
Treatment (meds & other interventions)
based on only this data!
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Quantitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
Q.S.T.
(Quantitative Sensory Testing)
Q.S.T.
(Quantitative Sensory Testing)
Device has changed names multiple times (to
avoid litigation and to optimize reimbursement)
Stimulation applied by probe to surface of
extremity (over dermatome).
Patient response REQUIRED (as stimulus
intensity ’s patient instructed to say “I feel it
now”).
Also called “voltage-actuated sensory nerve
conduction threshold” or vsNCT.
Q.S.T.
(Quantitative Sensory Testing)
Used & promoted by Pain Medicine Clinics
Usually have no EDX training
Anesthesiologists, FPs, IMs, Peds (?), etc.
Often used to justify need for injections
Largest company states is “97% sensitive
while standard EMG is 37% sensitive in
diagnosing radiculopathy”
Q.S.T.
(Quantitative Sensory Testing)
Supporters formed organization called
“American Association of Sensory
Electrodiagnostic Medicine”
When we were AAEM they were AASM
When we changed to AANEM they
changed to AASEM
Logo very similar to AANEM logo
(You draw your own conclusions)
Q.S.T.
(Quantitative Sensory Testing)
Previously billed as 95904 (Sensory Nerve).
Does not provide amplitude, duration, or
velocity (required to bill NCSs).
Even latency is confusing - ? Time to
patient response?
Made additions to device when printed
waveform required (“Potentiometer”)
Q.S.T.
(Quantitative Sensory Testing)
Try to make reports look like standard
NCS reports.
Never use term “Q.S.T.”
Use term “Nerve Conduction Studies”
Medicare and most Private Payers deem
“Investigational” and do not reimburse
(if they see thru the “disguise”!!).
Q.S.T.
(Quantitative Sensory Testing)
Despite new grouped NCS codes
inappropriate QST exams performed.
This is most likely due to many using
results to justify injections.
Q.S.T.
(Quantitative Sensory Testing)
Biggest deficiency of Q.S.T. is that
because of need for patient response it
is a SUBJECTIVE TEST.
Obviously the results can be changed or
biased by patient.
Important point to make to insurers or
others.
Q.S.T.
(Quantitative Sensory Testing)
Other Reasons QST Not Quality EDX
QST does not measure necessary response
parameters of amplitude, latency, configuration, AND
conduction velocity.
 Those performing do not have appropriate training,
education, experience, expertise, or credentials.
Make ludicrous and unsupported claims.
Need to address AMA-CPT and go through the
appropriate channels to get it’s own code.
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
Manipulation
of
Waveforms
Manipulation of Waveforms
Landmark case in New Jersey
Digital copies of waveforms reproduced
on multiple patients charts
Possibly fictitious patients
Altering waveforms to appear to be
obtaining new/different data
Manipulation of Waveforms
Alteration of Waveforms
Changes in instrumentation
Sweep speed
Gain
Changes in stimulation
Manually moving cursors
Relabeling as different side
Cutting & pasting waveforms
Manipulation of Waveforms
Alteration of Waveforms
Can make changes in report of:
Hardcopy waveforms
Digital waveforms
Numerical data in graphic form
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
“Mail Order EMG/NCS”
“Mail Order EMG/NCS”
Inadequate Training
Physicians
PTs
Technologists
Chiropractors
Medical Assistants
Receptionists
Your Mailman (Allow any paying customer)
“Mail Order EMG/NCS”
Weekend Courses (With Diploma)
DVD
Online Courses
Booklets/Written Course Materials
Half Day in Office Instruction
Teleconferences
“Mail Order EMG/NCS”
Some teach you to acquire the data and
then it is sent off to be interpreted.
Others teach you to acquire and
interpret the data.
Some courses include instruction in
“report writing” (esp. how to make
reports look like good quality report).
“Mail Order EMG/NCS”
Some companies sell small hand-held
NCS device that also performs EMG.
In weekend course you are instructed
in the performance and interpretation of
EMG exams.
“Mail Order EMG/NCS”
Some Claims of “Mail Order” Companies
“Learn how to perform EMGs from the
comfort of your home and on your
schedule. - Starting at $49.99”
“Stop referring patients out! Add EMG
to your practice today.”
“No cost to practice - in fact, testing
can generate significant revenues.”
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
Inappropriate CPT
95937 Billing
Inappropriate CPT 95937 Billing
CPT code 95937 = NMJ testing –
Repetitive Nerve Stimulation
30 minutes of time needed
(pre/work/post)
Only NCS billed as separate units –
(can be billed multiple times).
Historically reimbursed higher
Should only be for Myaesthenia Gravis
of Lambert-Eaton Syndrome
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
Types of EDX Fraud & Abuse
UNQUALIFIED
PRACTITIONERS
Unqualified Practitioners
Physical Therapists
APTA goal/mandate - to have all PTs
nationwide able to legally do EDX
Chiropractors
Have “added qualifications” in
Neurophysiology / NM medicine
Other MDs/DOs
(or office staff)
IM, FP, Podiatrist, Rheum, Ortho, Anes,
Pain Med
Recent LSBME case – Cardio, Pulm, Pod
Types of EDX Fraud & Abuse
Mobile EDX Laboratories
Hand-held Devices
QST (Qualitative Sensory Testing)
Manipulation of Waveforms
“Mail Order EMG/NCS”
Inappropriate CPT 95937 Billing
Unqualified Practitioners
“The Enemy Within Our Ranks”
“Enemy Within Our Ranks”
Neurology and PM&R Physicians
Participating in MDLs – (LSBME case)
Using HHDs, QST, “Mail-Order EMG”
Manipulating Waveforms
Inappropriately Supervising Techs
Allowing MAs, PAs, FNPs, PTs, or others
to do part or all of NCS/EMG.
“Enemy Within Our Ranks”
Some are AANEM members
Some are AAN or AAPM&R members
Some are ABEM certified!
They often tout these “credentials”
blatantly…
Addressing EDX
Fraud & Abuse
Addressing EDX Fraud & Abuse
Resources
EDX Laboratory Accreditation
“Red Flags” for Insurers
Addressing
EDX Fraud & Abuse
Resources
Addressing EDX Fraud & Abuse
RESOURCES
AANEM POSITION STATEMENTS
Proper Performance and Interpretation
of Electrodiagnostic Studies
Endorsed by AAPM&R & AAN
By describing what constitutes QUALITY
EDX studies it highlights inaccuracies,
insufficiencies, and inappropriateness of
MDLs, HHDs, and inadequately trained
individuals
Addressing EDX Fraud & Abuse
RESOURCES
AANEM POSITION STATEMENTS
Used by most all private insurers to
draft reimbursement policies
Used by CMS to make reimbursement
decisions – LCDs (NCD soon?)
Accepted authority on quality EDX
Use extensively in F&A cases
Addressing EDX Fraud & Abuse
RESOURCES
OTHER AANEM POSITION STATEMENTS
Recommended Policy for EDX Medicine
Model Policy for Needle EMG and NCSs
Quality EDX Medicine Controls Costs
Who is Qualified to Practice EDX Medicine?
Credentialing of Physicians as EDX
Consultants
Addressing EDX Fraud & Abuse
RESOURCES
OTHER AANEM POSITION STATEMENTS
Reporting Results for Needle EMG and NCSs
Guidelines for Ethical Behavior Relating to
Clinical Practice Issues in NM and EDX
Medicine
EDX services: Pay for Quality (new)
Most are endorsed by AAPM&R and AAN
Addressing
EDX Fraud & Abuse
EDX Laboratory
Accreditation
Addressing EDX Fraud & Abuse
EDX LAB ACREDITATION
Prompted by many Insurance Co. calls to
AANEM office
Endorsed by AAPM&R
Accreditation based on Quality
Separate from ABEM
Costs will pay for program to run
NOT designed as a money maker
Renew every 5 years
Voluntary
Addressing EDX Fraud & Abuse
EDX LAB ACREDITATION
Medical Director
CME requirement
Application procedure - online
Training requirements – PM&R residency
Physical facility requirements
Reports peer reviewed (a few)
Painless application process (Office Mgr can do!)
Addressing EDX Fraud & Abuse
EDX LAB ACREDITATION
Ensures quality EDX studies
Multiple mechanisms to keep out F & A
Insurance/Payers Acceptance
EDX studies authorized more easily
More EDX referrals
Better interactions / communications
?? Better reimbursement??
Addressing EDX Fraud & Abuse
EDX LAB ACREDITATION
All quality labs need to become accredited!
Working with private insurers and CMS:
? January 2016 Deadline
Only reimburse EDX studies done in an
accredited lab.
Possibly separate fee structure for accredited
and non-accredited labs.
Addressing EDX Fraud & Abuse
EDX LAB ACREDITATION
Our way to “take back” our specialty!
Sleep labs & Mammography are just a
few that did this with positive results.
For anyone in this room it is EASY!
May need legislation – been to Capitol
Hill twice already.
No Good Reason Not To Do It !!
Addressing
EDX Fraud & Abuse
EDX Fraud Trends
&
“Red Flags”
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Presentations to FBI, OIG, CMS, NHCAA and
multiple Private Insurers
 I tell them what to look for – how to find
EDX F&A
EDX practices that have any of these “red
flags” will be at higher risk of review, audit,
claim denials, or prosecution.
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
In 2013 (and 2014) EDX studies are on
the OIG’s “Hit List” (Office of Inspector
General Work Plan).
“The use of EDX testing for inappropriate
financial gain poses a growing vulnerability
to Medicare.”
(Not small potatoes anymore!)
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
AMA-CPT Coding Book Change for 2013
“Waveforms must be reviewed on site
in real time, and the technique must be
adjusted, as appropriate, as the test
proceeds…”
“Reports must be prepared on site by
the examiner…”
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Growing movement to require physician
billing EDX studies to have residency
training in PM&R or Neurology.
LCD’s – Medicare Regional Carriers
NCD’s – Medicare nationally
Private health insurances coverage policies
“Scope of Practice” issue poses problem
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Limiting reimbursement to
PM&R & Neuro physicans only
would have
THE LARGEST
effect on EDX Fraud & Abuse
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Before 1/1/13
Excess # nerve studies – esp. 95900,
95903, 95904
Excess $ charged per nerve study
“Open Season” for NCS billing!!!
After 1/1/13
Grouped/Bundled NCS billing schedule
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
After 1/1/13
1-2 nerve conduction studies = 95907
3-4 nerve conduction studies = 95908
5-6 nerve conduction studies = 95909
7-8 nerve conduction studies = 95910
9-10 nerve conduction studies = 95911
11-12 nerve conduction studies = 95912
13 + nerve conduction studies = 95913
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Too many NCS performed
billing 95913 > 70%
Scheduling patients to perform NCS’s
on separate limbs on separate days.
UE split from LE can be acceptable
Lack of appropriate training/expertise
of MD/DO or NCS Technician
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Use of inappropriate EDX equipment
(e.g. – QST device or Hand Held
Device)
Insurers requesting EDX equipment brand,
model and possibly serial #
Look for NCS billed without EMG
<10% of time acceptable
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Repeating EDX studies for “monitoring”
Esp. seen with generalized neuropathy
No medical evidence to support this practice
Sometimes every 3-6 months!
Can be seen with other diagnoses
Possibly appropriate in nerve trauma
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Billing CPT 95937 Inappropriately
NMJ testing – Repetitive Nerve Stimulation
30 minutes of time needed
(pre/work/post)
Only NCS billed as separate (therefore
multiple) units.
Historically reimbursed higher
Should only be for NMJ disorders
(Myaesthenia Gravis of Lambert-Eaton)
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Lack of medical necessity for NCS/EMG
Professional and technical components
billed separately
Promotion to Health Care Providers
(MDs and others) as “money maker”.
Location of services not in office of NCS
reviewer/biller.
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Surface EMG disguised and billed as
Needle/Pin EMG
NCS waveforms reviewed at later time
NCS waveforms reviewed far away
NCS waveforms being duplicated or
manipulated
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
What % of EDX studies billed are NCS ONLY?
PM&R = 5%
Neuro = 10%
IDTFs = 80%
Podiatry = 100%
CBR201406: Electrodiagnostic Testing
Dates of Service 1/1/2013 – 12/31/2013
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
What % of EDX studies billed are NCS ONLY?
24 Specialties = > 30%
15 Specialties = > 50%
20% cut-off excludes all providers who
inappropriately perform only NCS
Addressing EDX Fraud & Abuse
EDX FRAUD TRENDS & RED FLAGS
Average Weighted NCS Services
per Beneficiary
PM&R = 7.74
Neuro = 8.45
IDTF = 14.07
(s with sicker/more complicated patients –
But that is NOT why IDTFs are so high)
Addressing EDX Fraud & Abuse
If you encounter F & A or if you are asked to
review cases of suspected F&A
Feel free to contact me
(541) 621-2297
peter@petergrantmd.com
Contact AAPM&R or AANEM staff
AAPM&R – Jennie Jackson (Manager, Health
Finance & Reimbursement)
AANEM – Millie Birr (Health Policy Director)

similar documents