Federal Reports

We found that the Institute of Education Sciences (IES) did not effectively implement Department requirements for the contractor personnel security screening process. We specifically noted weaknesses in IES’s development of internal policies and procedures, designation of contractpositions and position risk levels, notification and maintenance of security screening decisions and other related information, and inclusion of required contract provisions in contract solicitations. We found that IES staff and officials involved in the process were generally unaware ofDepartment requirements and their related responsibilities for processing contractor employees’ security screenings. We also determined that IES has not ensured that all contractor employees have appropriate security screenings and that security screenings are initiated in a timely manner.

The Centers for Medicare & Medicaid Services (CMS) developed the National Correct Coding Initiative (NCCI) to promote correct coding by providers and to prevent Medicare payments for improperly coded services. The NCCI edits include procedure-to-procedure edits that define pairs of HCPCS/Current Procedural Terminology codes (code pairs) that generally should not be reported together for the same beneficiary on the same date of service. One function of the procedure-to-procedure edits is to prevent payments for codes that report overlapping services except in those instances where the services are "separate and distinct" (e.g., different session or patient encounter). Typically, an NCCI edit would prevent the payment for a right heart catheterization (RHC) when billed on the same claim as a heart biopsy. However, under certain circumstances, a hospital may bill and get paid for both services in an NCCI code pair by including a modifier on the claim. If a hospital included modifier -59, it would bypass the NCCI edit and receive payment for both procedures as though they were performed separately. A hospital should not append modifier -59 to the HCPCS code representing an RHC when it is performed with a heart biopsy unless the procedures are separate and distinct.