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UDT+SVT = $126,800

If your practice performs urine drug tests (UDT), make sure you didn’t accidentally report specimen validity testing (SVT) performed as part of the test. And if your review does reveal any claims, remember that it could be worse. Medicare pays a few dollars for the tests and writing a check for an overpayment will likely be less painful than writing a check for a settlement, as a Florence, Ky., pain practice recently discovered. Northern Kentucky Center for Pain Relief, agreed to pay almost $126,800, to resolve allegations that the practice improperly billed for SVT, the HHS Office of Inspector General (OIG) announced Jan. 24.
This probably isn’t the last settlement investigators will wring from a provider who improperly reported the service. SVT is on the government’s radar and CMS issued a number of reminders that it is included in UDT. Here’s a brief overview of UDT/SVT oversight:
  1. A few Medicare administrative contractors (MACs) issued guidance stating that SVT was included in UDT in 2014.
  2. The Correct Coding Initiative manual added guidance instructing providers that SVT was included in UDT, effective Jan. 1, 2015.
  3. Effective Jan. 1, 2016, SVT was included in all descriptors for urine drug tests reported to Medicare.
  4. The HHS Office of Inspector General (OIG) published an audit report February 2018 which revealed that between 2014 and 2016 providers had received $66 million in improper payments for SVT. Nearly $2 million in improper payments were paid in 2016, after the implementation of edits designed to stop improper reporting of SVT. The majority of those claims came from doctors that performed urine drug tests.
  5. CMS issued a MLN matters article reminding practices that they may not report SVT with UDT, March 30, 2018.
The abundance of guidance makes it very hard for a practice to claim it had no way to know that it shouldn’t report SVT. At the same time, the guidance makes it very easy investigators to claim a practice knew or should have known it was billing improperly and that the improper claims constitute fraud.
Blog Tags: anti-fraud, CMS, OIG
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