Madison-based University of Wisconsin Hospital and Clinics submitted erroneous bills to Medicare for treatment of severe malnutrition, according to a recent report from HHS' Office of Inspector General.
The hospital failed to comply with Medicare billing requirements for 90 of 100 severe malnutrition claims audited by the OIG. The medical record documentation supported a secondary diagnosis other than a severe malnutrition diagnosis code for two of the 90 claims, but the errors did not change the payment the hospital received. For the remaining 88 claims, the billing errors resulted in overpayments of $562,361, according to the OIG.
For the audit, which covered claims submitted from 2014 through 2016, the OIG reviewed a random sample of 100 claims totaling $1.8 million. Extrapolating from the sample results, the OIG estimated UW Hospital and Clinics received $2.4 million in combined overpayments during the audit period.
Based on its findings, the OIG recommended UW Hospital and Clinics refund the Medicare contractor $2.4 million, exercise reasonable diligence to identify and return any additional overpayments outside of the audit period, and strengthen controls to ensure full compliance with Medicare requirements.
In written comments on the OIG's draft report, the hospital agreed that three of the 88 claims for which there was a change in diagnosis-related group included a diagnosis code for severe malnutrition that resulted in a billing error. However, the hospital did not agree with the OIG's determination that the remaining 85 of these claims were billed incorrectly. In addition, UW Hospital and Clinics said the guidance used for the review was vague, and that the OIG did not specify any standard for the hospital to use in diagnosing severe malnutrition.
"UW Health uses the most up-to-date definition of malnutrition and current methodology for assessing malnutrition," the hospital said in a statement to Becker's Hospital Review. "Several international nutrition organizations have published evidence-based guidelines for diagnosing and coding malnutrition, and UW Health uses a metric that incorporates these current understandings."
After reviewing the hospital's written comments on the draft report, the OIG maintained its findings and recommendations. The hospital said it plans to appeal all claims denied based on the OIG recommendations.
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