OIG Sending Out Letters Seeking Informal Resolution

TDMR has learned that a number of Medicaid dentists around the state have been receiving informal letters from the Office of Inspector General about their billings.

Avoid formal process

Apparently, OIG is looking to resolve billing situations informally rather than go through the formal demand process which might lead to expensive SOAH hearings and legal costs for all parties involved. It is believed that certain providers have been targeted using data mining techniques which look for outliers in billing.

Some of the more prevalent areas of review are sedation, sedation documentation (such as oral sedation, dosage and supervision, patient supervision, tapes and start/stop times), dental work billed out but allegedly not performed, x-ray quality and missing documentation (i.e., no patient file submitted).  An area of vulnerability for some providers may be gaps in documentation prior to electronic health records becoming universal.

Not bad for providers

This method employed by OIG is not bad for providers.  Informal settlement conferences are certainly preferred to the formal demand process and its strictures.  One problem is that OIG will not provide a spreadsheet with billing amounts that are problematic because this would start a formal process so they provide one without figures.

Settlement negotiable

In a case we have been made aware of, OIG was interested in settling informally and was even willing to accept a lower settlement amount as long as the federal share was covered.  They provided time to pay with negotiable interest.  The settlement covered all claims for the time period involved and there was no admission of wrongdoing.

With such settlements, all installments go to pay off the principal first before interest is paid.  So one can even pay in half the time and avoid half the interest.

This is a much better process for all involved.

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