The medical center self-reported violations at four outpatient surgery centers, according to a Nov. 4 Justice Department news release. Horizon disclosed that it failed to include a “PN” modifier and location to identify services performed at non-excepted, off-campus outpatient facilities when submitting claims to Medicare.
Horizon also disclosed that it had entered into management agreements with third-party companies affiliated with physicians performing surgeries at its outpatient facilities. It also leased equipment through operating agreements with companies affiliated with those same physicians.
As part of its disclosure, Horizon included an analysis conducted by an independent third-party expert to assess the financial impact of omitting the required modifier.
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