Last week, U.S. Attorney's Office for the Northern District of Iowa and the University of Iowa (UI) entered into a settlement agreement to resolve allegations that UI's academic medical center in Iowa City, Iowa, had submitted certain improper claims for payment to the Medicare program. The allegations related to claims for diagnostic radiology interpretations performed by resident physicians which were submitted under an attending teaching physician’s billing number. The government alleged that the review of the residents’ interpretations by the teaching physicians did not satisfy government payment requirements for such teaching physician services. Under the terms of the settlement agreement, UI agreed.to increased compliance training and the payment of $16,444 to the United States.
Quoting the press release: "Specifically, the government alleged that it had certain civil claims against UI arising from its submission of claims for payment for resident x-ray interpretations, where review by an attending physician did not satisfy the requirements of 42 C.F.R. § 415.180, between the period July 2018 to May 2020. Under 42 C.F.R. § 415.180, a Medicare payment regulation identifying requirements for the interpretation of diagnostic radiology in a teaching setting, physician fee schedule payment may be made for x-ray interpretations if the interpretation is reviewed or performed by a physician other than a resident."
Medicare rules expect that diagnostic imaging interpretations performed by resident be billed as physician services only when the attending teaching radiologist also personally reviews images and the resident's interpretation and either "agrees with it or edits" the findings. It is not permissible for teaching physicians to only sign off on resident's interpretations without documenting their own physician work. See Medicare Claims Processing Manual, Chapter 12, § 100.1.2 (A)(6).
Despite the relatively small amount of the UI settlement agreement, it provides an important compliance reminder to all radiology teaching programs. Attending radiologists must personally review imaging examinations and their resident's radiology reports, and they must document their agreement with the report, or document that they edited the report, in order to be eligible to bill for these professional services.