Last month, TDMR reported on the Texas Health and Human Services Office of Inspector General Quarterly Report for the fourth quarter of 2019. A highlighted topic in the report was the Illegal solicitation of patients by dental providers.
Didn’t know about advisory
We just discovered that OIG issued a Fraud and Abuse Prevention Advisory back in August. So we thought we should provide this to the Medicaid dental community as well.
It is not clear how such advisories are distributed because we are on the HHS-OIG email list and never received any notification about it whatsoever.
Important data on solicitation cases
There are several important points that should be noted based on further research. An OIG powerpoint presentation from June 2019 on their website shows:
A. The complaints about solicitation referrals come primarily from the public.
- 75% of cases referred by Public/Anonymous.
- 11% of cases referred by Provider
- 8% of cases referred by DMOs.
B. That 22% of OIG dental investigations have solicitation as a component of concern from 2017 to date.
C. The primary data indicator of illegal solicitation is patients changing providers.
- 11% of client population had a possibility of having switched due to solicitation.
- The 11% of the clients were billed by 86% of the providers.
- Client movement involves a minority of clients yet a majority of providers.
D. As reported back in October, the prime suspects are:
- 1% of provider population had a higher risk score
- 85% are group providers
- 15% are individual providers
- 60% located in DFW area
- 15% located in Houston area
However, El Paso, McAllen-Edinburg-Mission and San Antonio are locations that also have suspect providers.
Here is the advisory: