| OIG lists the following items as specific regulatory risks most frequently subject to investigation and audit: |
| 1. |
Billing for items or services not rendered |
| 2. |
Submitting claims for supplies and services that are not reasonable and necessary |
| 3. |
Double billing |
| 4. |
Billing for non-covered services Bitmap |
| 5. |
Failure to properly use coding modifiers |
| 6. |
"Clustering" (using only a few codes on the theory that it will average out) |
| 7. |
"Upcoding" (using a higher reimbursement code than the code reflecting the service rendered) |
| 8. |
Inappropriate balance billing |
| 9. |
Routine waiver of co-payments and billing third-party insurance only |
| 10. |
Discounts and professional courtesy |
| 11. |
Improper billing for incident-to services |
| 13. |
Failure to refund credit balances due to patients and payers |
| 12. |
Improper reassignment of physician billing numbers |
| 14. |
Billing for services provided by unqualified or unlicensed clinical personnel |
