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FYI: OIG to check UDT for SUD

Practices that treat substance use disorders (SUD) and perform urine drug testing take note: The HHS Office of Inspector General (OIG) added urine drug tests for SUD patients to the agency's Work Plan in its October 2019 update.
Urine drug tests are an essential and separately billable part of treating (SUD) patients, but high billing error rates in 2018 are prompting a review.
The improper payment rate for the most expensive type of urine drug testing in 2018 reached 72%, the OIG stated in the Work Plan item. Expect the OIG to review test claims for patients with an ICD-10-CM diagnosis from the code family encompassing mental and behavioral disorders due to psychoactive substance use (F10-F19).
There are a few simple steps practices can take to pass an auditor's review:
  1. Make sure the medical record shows that the practice is actively treating the patient for an SUD.
  2. Stick to the frequency limits for SUD patients. The information is available in your Medicare administrative contractor’s (MAC) local coverage determination for urine drug testing.
  3. Bill the right test.
Presumptive drug tests
Presumptive drug tests indicate whether a sample is positive or negative for one or more classes of drugs. For example, a presumptive test can show a patient is positive for opiates. However, it can’t identify the kind of opiates.
Presumptive tests performed with an instrumented chemistry analyzer (80307) were the most common presumptive test performed in the office, according to Medicare Part B utilization data for 2018, the most recent data available.
As with all presumptive drug tests, the full descriptor spells out the equipment that is used, the type of analysis that is performed and that the service may only be billed once per patient per day, no matter how many samples or drug classes are analyzed:
  • 80307: Drug test(s), presumptive, any number of drug classes, any number of devices or procedures; by instrument chemistry analyzers (eg, utilizing immunoassay [eg, EIA, ELISA, EMIT, FPIA, IA, KIMS, RIA]), chromatography (eg, GC, HPLC), and mass spectrometry either with or without chromatography, (eg, DART, DESI, GC-MS, GC-MS/MS, LC-MS, LC-MS/MS, LDTD, MALDI, TOF) includes sample validation when performed, per date of service.
A practice that reports this code may be asked to prove it has an analyzer that meets the specs for the code.
Definitive drug tests
A definitive drug test may be necessary in the office when a presumptive test produces an unexpected positive or negative result. A definitive test is not medically necessary for an expected result, when the patient provides an explanation for an unexpected result or to check the accuracy of a presumptive test.
The definitive drug test cited in the Work Plan item – G0483 – was the most commonly performed definitive test in the office setting, according to Part B utilization data. Here’s the full descriptor for the code:
  • G0483: Drug test(s), definitive, utilizing (1) drug identification methods able to identify individual drugs and distinguish between structural isomers (but not necessarily stereoisomers), including, but not limited to GC/MS (any type, single or tandem) and LC/MS (any type, single or tandem and excluding immunoassays (e.g., IA, EIA, ELISA, EMIT, FPIA) and enzymatic methods (e.g., alcohol dehydrogenase)), (2) stable isotope or other universally recognized internal standards in all samples (e.g., to control for matrix effects, interferences and variations in signal strength), and (3) method or drug-specific calibration and matrix-matched quality control material (e.g., to control for instrument variations and mass spectral drift); qualitative or quantitative, all sources, includes specimen validity testing, per day; 22 or more drug class(es), including metabolite(s) if performed.
An audited practice may need to show that its lab equipment meets the code’s requirements and that each claim is backed by the results of a medically necessary presumptive drug test.
Blog Tags: compliance, OIG
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