Has your staff received the appropriate training or licensing/ certification to perform orthopedic procedures in your office?
Information from Medscape, edited for our orthopedic membership
October 10, 2011 — A watchdog agency in the US Department of Health and Human Services (HHS) wants to know how many office visits, consultations, eye exams, skin grafts and other services (casting) are performed by unqualified nonphysicians under Medicare’s “incident-to” billing rules.
This is just one new investigation that the HHS Office of Inspector General (OIG) plans to conduct next year, according to its annual work plan, which was published last week.
Incident-to billing in Medicare creates a financial incentive to delegate clinical duties, but the complicated rules governing such claims trip up the best intentioned. A physician can bill for an employee’s work as if the physician had performed it, as long as it is “incident to” the physician’s services.
Low-level office visits, drug injections, and blood draws are common examples of services that are billed incident-to and paid at 100% of Medicare’s physician fee schedule. However, for these claims to be up to snuff, the incident-to service must follow up on patient care initiated by the physician, who also must be on the premises to provide supervision and assistance (in group practices, a partner can suffice).
Busy physicians have drawn much of their Medicare reimbursement through incident-to billing. An OIG study in 2009 revealed that when Medicare allowed physicians to bill the program for more than 24 hours of service within a single day, nonphysicians had performed half the services.
The OIG finds no fault in that pattern. What bothers the OIG is that for 21% of the services that nonphysicians performed, the nonphysicians were not qualified to render them: They lacked needed licenses or certifications, verifiable credentials, or the appropriate training, according to the OIG.
In its 2012 work plan, the OIG stated that incident-to billing “may be vulnerable to overutilization and expose Medicare beneficiaries to care that does not meet professional standards of quality.” The OIG intends to determine whether incident-to claims have a higher error rate than ordinary ones, as well as assess the ability of CMS to monitor incident-to services, which are not identified as such on claims.
Related posts:


So what certifications do OIG recognize. Why is ASOP and not NAOT stating this issue? Just wondering.
Whos certification will OIG recognize?
For the record I would like to state that I attented the Orthopaedic Technician school in the US NAVY and its documented on my DD-214 (NEC-8489). NBCOT which is a member of NOCA and NCCA to my knowledge recognizes the US NAVY Orthopaedic Technology School. With that being said, I think all military trained Ortho Techs should be just fine.
ABOUT NOCA AND NCCA
About the National Organization for Competency Assurance (NOCA)
NOCA originates from the 1977 congressional creation of the National Commission for Health
Certifying Agencies (NCHCA). With federal funding made available through the Department of
Health and Human Services, its mission was to develop standards for quality certification in the
allied health fields and to accredit organizations that met those standards.
With the growing use of certification in other fields, the NCHCA leadership recognized that what
was essential for quality certification of individuals in the healthcare sector was equally essential for
other sectors. Hence, NCHCA evolved into the National Organization for Competency Assurance.
NOCA is a non-profit, 501(c)(3) organization. NOCA member organizations represent the leaders
in the certification field. These organizations certify occupational skills in sectors ranging from
healthcare to technology to manufacturing and construction.
Membership in NOCA offers a forum for professional development of the certification professional
and opportunities to learn about competency assurance issues and other best practices for the field
of certification. Membership in NOCA does not require any review of certification activity or
adherence to any specific standards. NOCA membership is open to all disciplines and professions.
NOCA and the National Commission for Certifying Agencies (NCCA)
NCCA was created to establish national voluntary certification program standards and recognize
compliance with these standards. NCCA is an accrediting entity and is not a membership
organization.
NCCA uses a peer review process to evaluate adherence to its standards and grant recognition
through accreditation to those organizations judged to have met those standards. NCCA is the only
national accreditation body that provides this service for private certification organizations in all
disciplines.
Organizations that seek NCCA accreditation do so voluntarily, as a means of enhancing the
reputation and marketability of their certification. Fifteen percent of the membership of NOCA
have achieved NCCA accreditation.
• NCCA accreditation is a voluntary opportunity for certification programs to achieve recognition
for meeting the highest standards of competency assurance.
• The cost associated with achieving NCCA accreditation is intended to cover expenses directly
associated with program evaluation.
• Individual reviewers, who are volunteer professionals in the certification field drawn from
NOCA member organizations are not compensated for their time.
At this time, that is unknown. But NAOT will not be one of them. They do not have a certification. They are only a membership organization.