Treatment/Assessment Plan Numbers to Become Mandatory on HCAI Invoices

On November 8, 2011, the Superintendent released a bulletin (A-07/11) outlining changes to the HCAI Guideline to address abusive billing practices including frequent invoices, duplicate invoices, "double dipping" and invoicing for non-approved goods and services .

At the time the Superintendent committed to further changes to the Standard Invoice (OCF-21) that would provide that the “Plan Number” on the form would become a mandatory field. This is the unique number generated by the HCAI system when the Treatment and Assessment Plan (OCF-18) or Treatment Confirmtion Form (OCF-23) to which the OCF-21 refers is submitted, and will enable insurers to properly reconcile invoices.

These changes have now been made and announced by the Superintendent in a recent bulletin (A-02/12). The updated HCAI system will become available at 8 a.m. EDT on July 3, 2012. At that point, HCAI will begin enforcing the new rules for OCF-21 submissions.

If there is no Plan Number because of a valid business scenario (e.g., the insurer has waived the requirement for an OCF-18 or OCF-23 as applicable) the word “exempt” must be inserted in the Plan Number field and details of the circumstances must be provided in the “Other Information” section of the OCF-21.

FSCO will in the near future be issuing an amended OCF-21 form to address information gaps a regarding Minor Injury Guideline (MIG) claims. These changes will be effective for use on and after November 1, 2012 and will contain the following changes:

• The amended OCF-21C form will include two new mandatory additional data fields in which the date that the MIG treatment Block commenced and the profession(s) of the health care provider(s) who provided the treatment are to be identified. In addition, use of the OCF-21C will become mandatory for billing all amounts applicable under the MIG. The OCF-21B and OCF-18 will no longer be approved for use with MIG codes.
  
  
• The amended OCF-21 form will also reflect the requirement, already noted above, that completion of the “Plan Number” field in the manner specified in the Guideline is mandatory effective July 1, 2012.
  
  
• In addition, the OCF-21 will be amended to raise the awareness of those individuals signing the form of their responsibility and accountability in doing so.

The revised HCAI Guideline (No.2/12) can be found here.

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