Review of Outpatient Cardiac Rehabilitation Services - Saint Luke's Medical Center, Milwaukee, Wisconsin

The objective of this review was to determine whether Saint Luke's Medical Center (SLMC) currently claimed Medicare reimbursement for outpatient cardiac rehabilitation services.  We found that SLMC did not designate a physician to directly supervise the services provided under its cardiac rehabilitation program.  In addition, contrary to Medicare requirements, we could not identify the physician professional services to which the cardiac rehabilitation services were provided “incident to.”  Based on a statistical sample, we estimated that SLMC claimed and received Medicare reimbursement for outpatient cardiac rehabilitation services, of approximately $47,247, which did not meet Medicare coverage requirements, which may not have been supported by medical record documentation, or which was otherwise unallowable.  We recommended that SLMC work with its fiscal intermediary to ensure that its outpatient cardiac rehabilitation program is conducted in accordance with the Medicare coverage requirements, and to establish the amount of repayment liability, estimated to be approximately $47,247.  We also made procedural recommendations for internal control improvements.