Fletcher Allen Health Care Did Not Always Bill Correctly for Evaluation and Management Services Related to Eye Injection Procedures

Fletcher Allen Health Care (the Hospital), located in Burlington, Vermont, and its physicians complied with Medicare requirements for 15 of the 100 Evaluation and Management (E&M) services that we sampled. However, the Hospital incorrectly billed for the remaining 85 services, resulting in overpayments totaling $8,100. Based on these sample results, we estimated that the Hospital and its physicians received overpayments totaling $211,000 for calendar years 2008 through 2010. Overpayments occurred because the Hospital had inadequate billing system controls over billing E&M services related to outpatient eye injection procedures, and the Hospital's physicians, who performed the eye injection procedures, did not fully understand the Medicare requirements for separately billable E&M services.