John Falcetano (john.falcetano@brooksrehab.org) is Director Corporate Compliance at Brooks Health System in Jacksonville, FL.

A critical element of any effective compliance program is monitoring. As a service to our members, each month this column focuses on potential monitors for specific business lines.

In the May 2019 column, we discussed conducting probe samples to identify potential monitors. This time we will focus on using government audit results to identify potential monitors for outpatient physical therapy services. In 2018, the Office of Inspector General (OIG) released an audit report that showed that many of the Medicare claims for outpatient physical therapy services did not comply with Medicare requirements. The OIG report stated that in a sample of 300 claims, 61% did not meet the requirements for medical necessity, coding, or documentation.