HBOT: The Office of Inspector General’s Most Wanted?
by Thomas E. Serena MD, FACS, FACHM, FAPWCA
In 1950, J. Edgar Hoover published the first edition of the FBI’s most wanted list. Since that time, no less than 512 fugitives have been featured. Many surrendered after learning that their mug shots were hanging on every post office wall in the country. In medicine, we have an equally infamous public posting: The Office of Inspector General’s (OIG) work list. In 2017, it turns out that hyperbaric medicine services are "public enemy number one." But please, do not surrender just yet.
Hyperbaric Oxygen Therapy Under Investigation
This OIG investigation should come as no surprise to anyone even moderately informed of developments in the wound care space—there have been few areas subject to more abuse. A natural consequence: whistle blower lawsuits have drawn increased attention to hyperbaric oxygen therapy (HBOT), alleging that doctors and staff members were pressured, cajoled, threatened, transferred, and terminated in a concentrated program to increase HBOT volumes. And the "Wanted Posters" can be found in the OIG Work Plan for 2017.
The OIG listed three specific investigative areas of concern: beneficiaries received hyperbaric services for non-covered conditions, documentation did not support the use of HBOT, and patients received more hyperbaric treatments than were medically necessary.
So, the Feds are coming and the battle lines are drawn. The basic issue? Survival!
The solution to emerging whole from the coming scrutiny hinges on proper documentation. And, as in any investigation or audit, the person with the best data wins. The electronic health record must capture all of the elements required to meet medical necessity, as outlined in Medicare’s published coverage determination. Moreover, during treatment, there must be documented clinical improvement to justify additional dives. Does your EHR effectively and efficiently gather this information?
HBOT Prior Authorization and Wound Documentation
Over the past eighteen months, we have learned a great deal from the states requiring prior authorization for HBOT, primarily New Jersey. The dogmatic interpretation of the local coverage determination (LCD) in this state necessitated increasing the detail of our documentation, and instituting quality technology measures in the clinic itself to ensure that the appropriate tests were easily found in the wound-specific EHR. Also, we learned that free text frequently confuses the clinical picture, and often leads to denials. Our EMR program requires no free text, and in fact, discourages it.
In addition to meticulous documentation, we added technology in our centers to gather the required information in an expeditious fashion. These include objective testing for vascular disease, nutritional screening, and measurement of perfusion. The patient’s record clearly reflects that these tests were performed and the results addressed prior to recommending HBOT.
We recently had accepted for publication in Wound Repair and Regeneration a manuscript detailing our learning health care system.1 For more information about using an electronic health record for prior authorization, or assuring appropriate documentation, please feel free to contact me. Our proprietary quality technology system is available to SerenaGroup® sites and affiliates.
1. A New Approach to Clinical Research: Integrating Clinical Care, Quality Reporting, and Research Using a Wound Care Network-Based Learning Healthcare System. Scheduled for publication in Wound Repair and Regeneration.
About The Author
Dr. Thomas Serena has published more than 75 peer-reviewed papers and has made in excess of 200 presentations worldwide. He has been elected to the Board of Directors of both The Wound Healing Society and the American College of Hyperbaric Medicine (ACHM), the leading academic society in the field of Hyperbaric Medicine. In 2013 Dr. Serena was elected vice president of the American Professional Wound Care Association (APWCA). Dr. Serena has opened and operates Wound Care and hyperbaric oxygen treatment clinics across the United S
The views and opinions expressed in this blog are solely those of the author, and do not represent the views of WoundSource, Kestrel Health Information, Inc., its affiliates, or subsidiary companies.