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Labs Face Scrutiny From OIG Regarding COVID-19 Add-On Testing


On December 6th, the OIG published a report finding 44% of labs that billed Medicare Part B for COVID-19 tests billed for “add-on” tests. In addition, several outlier labs were identified with questionable billing practices raising concerns of fraud. Compared to their peers, these labs billed – and received – proportionally larger compensation for COVID-19 related care. 

Today, the OIG has made clear its intent to audit and recoup provided funds deemed outside the scope of its original mandate. When looking at recent government actions regarding COVID-19, it’s clear this retroactive scrutiny is only to accelerate as we head further into 2023:

  • April 20, 2022 - the U.S. Department of Justice (DOJ) announced a nationwide coordinated law enforcement action to combat health care-related COVID-19 fraud.
  • December 6, 2022 - the Office of Inspector General (OIG) published a report about labs with questionably high billing for additional tests alongside COVID-19 tests.
  • … and several OIG enforcement actions already taken against healthcare providers. 

OIG’s Latest Report Confirms Laboratory Billing Practices are Being Reviewed, what does that mean for my lab?

As the OIG’s audits and investigations ramp up, labs should preemptively determine the risk this increased scrutiny poses to their business. Preliminary questions to ask include: 

  1. Did my lab bill for add-on tests on claims for COVID-19 testing?
  2. If yes, how often – and under what conditions – did this occur? 
  3. Do I have the requisite documentation outlining the medical necessity to order add-on testing?

Determining the extent that additional add-on testing was ordered, and providing ample documentation supporting the medical need to do so, will be important should your lab be audited. For labs without adequate documentation, you will need to request documentation of medical necessity from ordering providers critical to successfully navigating an OIG audit. 

Laboratory consultants can perform internal investigations, gauge audit risk, and determine follow-up actions to ensure you remain compliant. 

Partner with Colaborate to Navigate the OIG’s COVID-19 Add-On Testing Audits

COVID-19 fraud-related investigations are ramping across the country and laboratories could be at risk of overpayment disputes and subsequent enforcement actions. If you believe your organization may be a target, seek assistance from the professional laboratory consultants at Colaborate. We have proudly served over 500 institutions ranging from health systems to clinical laboratories and more. We’ve worked with the most recognizable names in healthcare, and we look forward to working with you, too. 

Contact us today to get started.