Alleged Irregularities Regarding Physician Incentive Compensation Were Not Substantiated

In October 2018 and January 2019, the OIG received unrelated complaints of potential irregularities regarding physician incentive compensation at two different healthcare facilities. The OIG did not substantiate either complaint. The first complainant alleged that beginning in fiscal year 2018, the director of a cardiac catheterization lab misused his government position for personal gain by restricting other cardiologists’ access to the lab when creating the monthly schedule and by performing an increased number of procedures to satisfy a new relative value unit- (RVU-) driven productivity component of performance pay. Beginning in 2013, the lab director prepared the cardiology department’s monthly physician assignments schedule, including for the cardiac catheterization lab. In fiscal year 2018, the healthcare system in which the lab director worked introduced an incentive to increase productivity tied to the number of procedures performed. An OIG analysis of physician productivity data for fiscal years 2016 through 2019 did not substantiate that the lab director restricted other cardiologists’ access to the lab or performed an increased number of procedures to satisfy the RVU-driven productivity criteria that would increase his own performance pay. The second complainant alleged that a medical center’s dental service chief inappropriately miscoded numerous patient encounters to satisfy the RVU-driven productivity criteria component of his performance pay. The OIG determined that, while the dental service chief incorrectly coded several patient encounters, the coding errors were due to his inexperience with VA dental and medical coding procedures and had an insignificant impact on his overall performance pay. The OIG recommended that the medical center audit the performance pay received by the dental service chief to ensure that the errors did not result in any improper payments.