In 2015, ICD-10 finally became a reality, and the dire predictions of problems seem to be wrong. Providers now have codes to describe just about every conceivable (and a few simply bizarre) medical occurrences. If a patient is ever sucked into a jet engine, remember code V97.33XD, or if a patient is burned due to water-skis on fire (is that even possible?), code V91.07XD can be used. On a more serious note, this year may be viewed as the turning point for pay-for-value reimbursement, with CMS pursuing several new initiatives and private payers, including BCBS of Alabama and VIVA, implementing value-based payment programs for primary care physicians. As with other years, the government continues to aggressively pursue fraud, waste and abuse, with a reported return on investment of $7.70 for every dollar spent pursuing improper payments. According to the late Yogi Berra, "the future ain’t what it used to be." With that in mind, following are my top ten 2015 health care events for Alabama providers.

10. New OIG Rules and Guidance. -- This year brought a host of new rules and guidance in the area of fraud and abuse. In April, the Civil Monetary Penalty law was amended to give hospitals the green light to pay physicians to reduce Medicare costs by eliminating "medically unnecessary" services. Prior to the change, the law prohibited payment to limit any services, thereby calling into question many gain-sharing arrangements between hospitals and physicians. In addition, the OIG issued a new Fraud Alert in June, entitled "Physician Compensation Arrangements Should be Scrutinized", warning providers that compensation arrangements between referral sources must reflect fair market value for bona fide services. In September, the Department of Justice issued a Memorandum on individual accountability for corporate wrongdoing, signaling a new focus on holding corporate officers responsible for fraud and abuse violations within their organizations.

Originally published in Birmingham Medical News - December 2015.