Finding & Preventing Patterns in Health – An Australian Insurance Fraud Perspective
Transcription
Finding & Preventing Patterns in Health – An Australian Insurance Fraud Perspective
Finding & Preventing Patterns in Health Insurance Fraud – An Australian Perspective Health Insurance Counter Fraud Group Annual Conference, High Wycombe 3 November 2011 Michael Douman Head of Business & Clinical Analysis Bupa Australia Bupa Private and Confidential 13 October 2011 1 Medical Fraud – Frank Abagnale Bupa Private and Confidential 13 October 2011 2 Fraud Controls “We would be better served if Government policy was made not by Ph.Ds in economics but by grandmothers employing the skills they practice at the butcher’s” Bruce Vladek, Administrator, HCFA, 1980 “Any reasonably astute fraud perpetrator avoids detection by billing correctly, using orthodox treatments, and by avoiding excessive greed” Prof Malcolm Sparrow “License to Steal” (2000) “If a fraud perpetrator learns to bill correctly and thereby beats the edits and audits, then claims effectively bypass any chance of human inspection and will be paid” Prof Malcolm Sparrow, “Fraud in the U.S. health-care system” Social Research Winter 2008 “Fraud works best when claims processing works perfectly” “The rule for criminals is simple, if you want to steal from Medicare…or any other health care insurance program, learn to bill correctly” Prof Malcolm Sparrow, Testimony to the Committee on the Judiciary: Subcommittee on Crime and Drugs, U.S. Senate, 20 May, 2009. Bupa Private and Confidential 13 October 2011 3 On Jesuitical Casuistry and Fraud definitions • Your fraud is: • My desire to provide the patient the best possible service • My desire to avoid medical malpractice legal suits • My administrative error • My failure to understand the system/schedule/etc • My “utilising” the weaknesses in your product or contract design • Your effectiveness depends on: • What you measure • How you measure • How you count Bupa Private and Confidential 13 October 2011 4 Bupa Australia - Scale & Scope - 1 Lines of Businesses Bupa • Private Health Insurance • Corporate health and wellness • Chronic disease coaching • Home, travel, car and life insurance • Optometry and optical dispensing • Care services facilities Private and Confidential 13 October 2011 5 Bupa Australia - Scale & Scope - 2 • Bupa lives covered is 3,127,692* • 45.3% (10.3 million) of Australia has private health insurance of which Bupa’s market share is 27%* • Largely an ‘Individual Consumer Market’ of sales individual-pay 84% • Persons covered by top 4 Funds (Bupa, Medibank, HCF and NIB) is 76% • New members join through Retail centres, Web, Phone and corporate promotion • Extensive customer service touch points; Retail centres, Web, Phone and Corporate workplace Claims Operations* • High proportion of claims settled electronically 68% at point of service with ancillary claims being the highest at 81% • 19.6 million Ancillary Claims annually • 8.9 million Medical Claims annually • 1.1 million Hospital episodes annually * Data as at 30 June 2011 Bupa Private and Confidential 13 October 2011 6 Management Imperatives Improved Performance Return on Capital Employed Automation savings Revenue FLEXIBILITY Reduced claims payments Net Cash Flow SENSE OF URGENCY Operating Costs Personnel Reductions Customer Satisfaction Bupa Bupa Private and Confidential 13 October 2011 Private and Confidential 13 October 2011 7 ROI – Measuring & Tracking Savings • Do more savings represent success or failure ? • If you had rules & controls in the system, then you would not have the leakage in the first place Good practice • Funds actually recovered • Funds not paid out as a result of new rules, changes to product, changes to contracts, provider intervention • A deterrent effect on rest of industry (Hawthorn effect) is not calculated as part of the savings, as it is too difficult to separate out correlation from causation Bupa Private and Confidential 13 October 2011 8 Bupa’s Leakage Savings CY 99 to CY 10 Historical BCA Total Savings by Calendar Year $30,000,000 $27,000,000 $24,000,000 $21,000,000 Savings $18,000,000 $15,000,000 $12,000,000 $9,000,000 $6,000,000 $3,000,000 $0 1999 Series2 $2,193,987 • • • Bupa 2000 2001 2002 2003 $5,302,127 $6,807,438 $9,669,151 $9,534,873 2004 2005 2006 2007 2008 2009 2010 $11,201,232 $14,018,485 $13,188,703 $14,638,145 $17,977,826 $25,398,385 $28,456,324 Savings represent a multiple of >10 times BCA’s operating costs BCA savings 2010 are equal to 1% annual savings on hospital contracts, or 0.8% of total benefits paid BCA saves >$159 million over 11 years Private and Confidential 8 June 2011 9 Australian Health System Structure Australian Government PLAC TGA Prosthesis List Advisory Committee Therapeutic Goods Administration PBPA MBS Pharmaceutical Benefits Pricing Authority Medical Benefits Schedule ACCC Australian Competition & Consumer Commission Privacy Commission PBAC Prostheses List Pharmaceutical Benefits Advisory Committee Public PHIAC AHPRA Private Health Insurance Administration Council Australian Health Practitioner Regulation Agency PBS Pharmaceutical Benefits Scheme Doctors Hospitals PHIO Private Health Insurance Ombudsman Ancillary Providers Private State Health Departments Bupa Private and Confidential 13 October 2011 10 Country Health Systems determine what Funds need to/can do • Countries systems are different and we all have differing constraints under which we operate • What we do, or need to do, or cannot do, is a product of those national health systems • Health outlays formula is Benefits paid = utilisation*casemix*severity*price • The Australian scene is shown in high level detail in Patterns – Hospitals 1 • Unlike the public sector, in the private sector in Australia, due to Government rules, we have no control over: • hospital & medical & prosthesis utilisation • hospital casemix • casemix severity by contrast we do have controls in the ancillary area Bupa Private and Confidential 13 October 2011 11 Overview of PMI (PHI) Funds operations, Australia - 1 • Hospital – Facility, Prostheses, Pharmacy costs • No pre-authorisation unless it’s a Pre-existing ailment (PEA) issue • Funds are legislatively obliged to pay for most treatment • Government set minimum benefits are Fund payable if a contract cannot be agreed with a hospital • Prostheses use determined by the surgeon. The items & the price set by the Government • Pharmacy costs paid by Fund, Hospital, Government, or patient. • Outpatient costs not paid unless a contracted program with a hospital • Medical • Government determines the items paid (MBS Schedule), the rules governing them, and the price paid • Funds can pay a quantum in excess of 100% of the Government schedule fee Bupa Private and Confidential 10 October 2011 12 Overview of PMI (PHI) Funds operations, Australia - 2 • Product design requires Federal Government approval • Waiting Periods are regulated • Premiums charged for policies require Federal Government approval • Premiums are the same for all members on the same product whatever their risk • No one can be denied the right to join a Fund no matter what the clinical risks are • Privacy controls on access to medical records • Risk equalisation fund compensates for Funds having to accept all risks • Funds can determine: what ancillary specialty they pay for; the price they pay for a service; and limit utilisation • Specialties covered: Acupuncture, Aids & Appliances, Ambulance, Antenatal, Chiropractic, Dental, Dietetics, Funeral benefit, Hearing Aids, Home Nursing, Hypnotherapy, Living Well programs, Naturopathy, Occupational Therapy, Optical, Orthoptics, Osteopathy, Pharmacy, Physiotherapy, Podiatry, Psychology, Remedial Massage, Speech Therapy, Weight Watchers Bupa Private and Confidential 10 October 2011 13 Electronic Health Systems DOCTOR HOSPITAL ECLIPSE EDI MEDICARE BUPA AUSTRALIA CPOS (HICAPS, Isoft) ANCILLARY PROVIDER INTERNET MEMBER Impact of Automation on Fraud & Claims Leakage • Increasing automation is changing the way work is undertaken. • In the case of the increasing take up rate of Eclipse (hospitals and doctors) as well as existing Fund hospital EDI transmissions systems, the effectiveness of system controls and business rules are even more critical and encompasses: • • • • the accuracy of programming logic and parameter controls system controls reference tables System controls and rules are already significant in ancillary claims processing which account for 81% of claims processed Ancillary System Rules - Examples Bupa Private and Confidential 13 October 2011 16 Finding Needles in Haystacks BCA Data Sources SAS Datasets: 2,100 Boss Mirror: 680 tables Boss DW: 650 tables Hugo: 160 tables Diamond /MFM tables Other: ABS; AHIA; ARDRG; MBS; Prostheses; Providers; Own itemisation; Corporate Groups; MC/MF network etc BCA Server SAS FUTRIX Enterprise Guide -------------Data and reference tables updated DAILY Formats: 320 Futrix OLAP Tables: 2,800 Meta ReferenceTables: 90 SAS Catalogs • All our SAS datasets combined hold 4 billion rows of data • Lines of SAS code we maintain/have written: ~ 200,000 to 300,000 lines Bupa Private and Confidential 13 October 2011 17 Risk Assessment & Data Issues • Gatekeepers (providers) • Players (Members, Fund Employees) • Contracts, Products • System controls • Pareto principle - Size matters • It is possible to eliminate risk, but you may not end up with a viable business Data Issues • Data integrity • Metadata • Data classification • Data structuring Bupa Private and Confidential 13 October 2011 18 Risk Assessment • Providers as the gatekeepers are the major risk area • As automated systems become more important, members and employees can only “exploit” the manual system claims as per below: • Ancillary – Member & Fund Employee 18% • Medical – Member 23%, Fund Employee 14% • Hospital (Ex EDI and Eclipse) – Member & Fund Employee 0% • Other areas that require attention • Product design • system control weaknesses • contract provisions Bupa Private and Confidential 13 October 2011 19 Prospective Approaches • Rules & system controls based prevention • Hospital – clinical and/or business rules, contracts, products (Government constraints) • Medical – Medicare MBS rules, supplemented by Fund rules (Medicare constraints) eg type C reference tables • Prostheses – Fund rules eg warranties, UR eg frequencies, multiple charges • Ancillary – clinical and/or business rules, contracts, products • System auditing – “DOS attacks” • Examples of the preceding can be seen in the following slides At the end of the day companies accept a level of commercial risk as complete prevention is impossible unless you want to close down a business • Real time Behavioural profiling • This is a practice yet to occur in the Australian PHI scene Bupa Private and Confidential 13 October 2011 20 Retrospective Analytics Statistical Analytics • Data Mining • Trend analysis • Ratio analysis • Profiling & Benchmarking (providers, members, employees, products, services) • Statistical Standardisation • Scoring algorithms Non Statistical analytics • Targeted Clinical auditing • Coding audits • Etc Bupa Private and Confidential 13 October 2011 21 Kohonen Network (SOM) - Item model for popular dental items • Bupa Work undertaken with Deloitte’s some years ago Private and Confidential 13 October 2011 Kohonen Network (SOM) - Clustering and labels on popular dental items model Most expensive benefits • Value from this labelling can be substantial Most popular benefits ◦ allows comparison of items based on simultaneous consideration of 55 variables summarising their usage by members and providers ◦ What items are most like other items? • Input into item bundle analysis Zero schedule benefits with a high variability on amount paid Work undertaken with Deloitte’s some years ago Bupa Private and Confidential 13 October 2011 Zero paid benefits Patterns • A significant number of the more common patterns are shown in the appendices (slides 55-65). I don’t intend to discuss them here • A smaller selection are in the slides that follow • The industry in Australia is in the process of establishing a generic fraud pattern register to which all Funds have access • Some patterns can be employed by providers, members and Fund employees alone or in collusion with each other • Some patterns are employed by one of the 3 “players” • Generically they can centre on some form of over utilisation eg SPP, SPD, BPP, pathology and diagnostic tests, services per body part, treatment not in line with past history, bank account changes, • They can be found by analysing: outlier validity & frequency; benchmarking; non standard services; cluster analysis; age/service links; abnormal service times; non consistent patterns across products; different practices by same provider for same service at different locations; high usage items, providers, products, members, employees; service location/member residence location anomalies; link analysis of providers, members and employees; variable claims processing locations; Bupa Private and Confidential 13 October 2011 24 Questionable service Pattern 1 Bupa Private and Confidential 13 October 2011 25 Doctor Shopping–Model for Staff Fraud • Have dependencies on prescriptions drugs • Visit many GPs and pharmacies in different geographic areas High Risk High Risk Drug Drug Features User 1 User 2 Age 34.4 40 Mulitple Days 173.4 252.5 No of providers*** 199 413 Total Services 645.2 767.5 Analgesics*** 71.2 213 Benzodiazepenes*** 202 32 Codenes 124.2 169 No.of approvals*** 24.4 140 No of postcodes*** 59.6 169 Total items 33.8 32 Benefits $ 14,768 16,134 Bupa Private and Confidential 13 October 2011 Medium Risk Low Risk Drug Drug User User 37 28 4.4 1.9 22 18.2 63.6 36.4 0 0.13 5.4 3.8 4.9 7.31 5 4.4 9 7.31 20 12.9 1,536 830.6 Fraud Pattern - Membership Bupa Private and Confidential 13 October 2011 27 Abuse of Tooth ID when no controls Bupa Private and Confidential 13 October 2011 28 Same Address, Different Memberships Bupa Private and Confidential 13 October 2011 29 Creating False Memberships • Note the activity on 13 Nov & creation of 18 new policies from 9:11am to 11:03am. • Note closure on 19 Jan from 10:09 to 11:36 am. • Policies stay in force for a month Bupa Private and Confidential 13 October 2011 30 Knowledge and Skill Sets Skills • Clinical: medical, nursing, pharmacy, dental • Business: Finance, Economics, Health Economics • Actuarial • Health Informatics/Clinical coding • SAS programming • Statistics • Clinical consultants are on standby Personal traits • In built crap detector • High stress threshold Bupa Private and Confidential 13 October 2011 31 Technologies & Software • Virtualised quad core blade server 32 Gb RAM, 2 Tb data • Designed own data model & extract daily from the mainframe • SAS is fundamental to everything we do • SAS base is used for sophisticated programming • SAS Enterprise Guide is used for “basic” programming, data extraction, and reporting • SAS Enterprise Miner is used for data mining • Futrix is our major self service OLAP tool, and it uses SAS, Java, J Boss languages • We have developed in-house web applications viz Ultrasound – a scoring program (used for Claims Leakage analysis), Lasar (used for Comp & Damages recoveries) Bupa Private and Confidential 13 October 2011 32 Analytics Scoring Algorithms 1 Bupa Private and Confidential 13 October 2011 33 Lessons Learned/Best Practice Tips 1 • Follow the Pareto principle • There are distinct limits to rules based systems and claims analysis, no matter how sophisticated they are. • Automated behavioural profiling is the next step • Profitable products can still be abused • Fraud is opportunistic and you leave it alone to do more important things at a cost • Hawthorn (deterrent) effect does not work when people are desperate • Data - clean data, good metadata, well structured data Bupa Private and Confidential 13 October 2011 34 Lessons Learned/Best Practice Tips 2 • Staff who are/have: Good technical (business knowledge); Fascinated by data & can see patterns in it; Experienced in using programming software; Statistical understanding; Understand systems and system controls; Understand the law; Understand the need for “compromise”; Cope with stress and not being loved • Good software and hardware tools • Minimal dependence on IT departments • Selling the return on investment • Having a Sponsor Bupa Private and Confidential 13 October 2011 35 References Sparrow, M Testimony to the Committee on the Judiciary: Subcommittee on Crime and Drugs, U.S. Senate, May 20, 2009. Sparrow, M “Fraud in the U.S. health-care system” Social Research Winter 2008 Sparrow, M License to steal (Westview Press, 2000) Corr, W Testimony to the Committee on Appropriations Subcommittee on Labor, Health and Human Services, Education, and Related Agencies United States House of Representatives Thursday, March 04, 2010 Selden, TM “The distribution of public spending for health care in the United States, 2002” Health Affairs 27, no. 5 (2008) DHSS Health Care Fraud and Abuse Control Program Annual Report for Fiscal Year 2009 Maclntyre , Hudson LLP The financial cost of Healthcare fraud (2009) NHCAA The Problem of Health Care Fraud (2010) http://www.nhcaa.org/eweb/DynamicPage.aspx?webcode=anti_fraud _resource_centr&wpscode=TheProblemOfHCFraud U.K. - NAO International benchmark of fraud & error in social security systems 2006 Medicare Aust Annual report 2008 – 2009 Professional Services Review Annual report 2008 – 2009 The End QUESTIONS [email protected] Ph. +61 2 93239896 Mb. +61(0)417 259 582 Bupa Private and Confidential 13 October 2011 37 Appendices Bupa Private and Confidential 13 October 2011 38 PHI coverage in Australia • Persons covered by top 4 Funds (Bupa, Medibank, HCF and NIB) is 76% Bupa Private and Confidential 13 October 2011 39 Health Funding Sources - Australia Australia’s Health 2010 p.414 Bupa Private and Confidential 10 October 2011 40 System Framework - Australia • Federal & State Governments (legislation, funding, powers) – Regulatory Bodies – Private Health Insurance Administration Council (PHIAC) – Medicare eg MBS Schedule, Compliance reviews – Australian Health Practitioner Regulation Agency (AHPRA) all providers – Professional Review Division eg physicians/surgeons registration/prosecution – Therapeutic Goods Administration eg approval to use drugs, prostheses – Pharmaceutical Benefits Pricing Authority (PBPA) – Prostheses List Advisory Committee (PLAC) – Private Health Insurance Ombudsman (PHIO) – Privacy Commission – Australian Competition and Consumer Commission (ACCC) • Public/Private Sector interface Bupa Private and Confidential 10 October 2011 41 Constraints on PMI (PHI) Funds operations, Australia - 1 • Hospital – Facility, Prostheses, Pharmacy costs • No pre-authorisation unless it’s a Pre-existing ailment (PEA) issue • If a treatment is paid on a Fee for Service (FFS) basis, Funds are legislatively obliged to pay for treatment and associated services provided, unless it has been excluded by product design or contract • Default benefits are Fund payable if a contract cannot be agreed with a hospital • Prostheses use determined by the surgeon. The items & the price set by the Government • Pharmacy costs paid by Fund &/or Hospital if a restricted PBS drug (whose use on a case by case basis the DoHA approves) or a non PBS drug • Electronic Claim Lodgment and Information Processing Service Environment (Eclipse) electronic claiming system use “mandatory” • Clinical and claims data submission to Federal Government mandatory • Outpatient costs not paid unless contracted with a hospital – Government responsibility Bupa Private and Confidential 10 October 2011 42 Constraints on PMI (PHI) Funds operations, Australia - 2 • Medical • Government determines the items paid (MBS Schedule), the rules governing them, and the price paid • If an MBS service is provided by a physician/surgeon in hospital then the Fund is obliged to pay it • 25% of the Government schedule price only paid by a Fund if they occur in a hospital • Government pays 75% of the Government set schedule price for a hospital episode (85% if an outpatient) • Funds can pay a quantum in excess of 100% of the Government schedule fee (ie the base 25% plus an additional percentage above 100%) to eliminate a member gap payment, where there is an agreement between the physician/surgeon and the Fund • Eclipse & Medicare 2 Way use “mandatory” • Outpatient costs not paid unless contracted with a hospital – Government responsibility Bupa Private and Confidential 10 October 2011 43 Constraints on PMI (PHI) Funds operations, Australia - 3 • Other constraints • Product design requires Federal Government approval • Waiting Periods are regulated • Premiums charged for policies require Federal Government approval • Premiums are the same for all members on the same product whatever their risk • No one can be denied the right to join a Fund no matter what the clinical risks are • Privacy controls on access to medical records Bupa Private and Confidential 10 October 2011 44 “Freedom” for PMI (PHI) Funds operations, Australia - 1 • Hospital • How a hospital admission, and its duration, are paid by a Fund, is determined by the Fund in negotiation with the hospital • The price paid for an ARDRG is that negotiated between the Fund and the hospital • The price paid for a “program” is that negotiated between the Fund and the hospital • Readmissions & inter hospital transfers payments are determined by the Fund in negotiation with the hospital, • Pharmacy costs paid by Fund and/or a hospital if a non PBS or restricted PBS drug. High cost drugs payment eg cancer, are signed off in advance by the Fund • Emergency ward treatment in a private hospital is not paid unless the patient is admitted • Risk equalisation fund compensates for Funds having to accept all risks Bupa Private and Confidential 10 October 2011 45 “Freedom” for PMI (PHI) Funds operations, Australia - 2 • Ancillary • Funds can determine what specialties they will pay for - see list below • Funds can determine what specialty services they pay for • Funds can determine the price they pay for a specialty service • Funds can limit utilisation of a service through product rules, business and/or clinical rules, or setting an annual benefit cap or rolling year benefit cap • Funds can determine the providers they deal with (commercial recognition rules), how they deal with them (EFTPOS and non EFTPOS) and the basis on which they recognise and register them • Funds can determine who is included in a (preferred) provider network and the basis of reimbursement and operation within a network • Specialties covered: • Acupuncture, Aids & Appliances, Ambulance, Antenatal, Chiropractic, Dental, Dietetics, Funeral benefit, Hearing Aids, Home Nursing, Hypnotherapy, Living Well programs, Naturopathy, Occupational Therapy, Optical, Orthoptics, Osteopathy, Pharmacy, Physiotherapy, Podiatry, Psychology, Remedial Massage, Speech Therapy, Weight Watchers Bupa Private and Confidential 10 October 2011 46 Government support for PMI/PHI • Private health insurance premiums subsidised by the Federal Government through rebates (35 per cent for those aged over 65, 40 per cent for over 70s, and 30 per cent for all others) • Lifetime Health Cover “obliges” people to join before 1 July after they turn 31 if they don’t want to have a loading of 2% on their premium commencing at age 30. This increases annually with joining age. • Medicare Levy Surcharge at 1% of taxable income is imposed on people whose income level is above $80,000 single & $160,000 couple if they do not take out health insurance • Subsidised public hospital treatment for PMI/PHI patients who: ◦ do not declare their PMI/PHI status up to 100%. ◦ do declare their PMI/PHI status through cheaper accommodation costs up to 67% of the private hospital bed day rate (public $320 vs private $965 in 2011) ◦ 12.6% of all private hospital admissions (private & public hospitals) are declared private patients in a public hospital. ◦ Previous analysis has shown that the percentage of PHI members who do not declare their PHI status accounts for 14% Bupa Private and Confidential 10 October 2011 47 Bupa & BCA Structure Bupa U.K. Bupa International Bupa Australia Board Board Audit Committee Internal Audit CFO CIO Director HR CMO Director HBM Business & Clinical Analysis Risk & Compliance Legal Claims Utilisation Review Information Analysis CEO Director Marketing & Product Director Sales Travel Branches Sales Staff Information Delivery BCA staff are based in Adelaide, Brisbane, Sydney Bupa Private and Confidential 13 October 2011 Director Customer Service Claims Membership Contact Centres Director Strategy BCA Teams BCA Michael Douman Information Analytics Rai Gomes Clinical Utilisation Review Margaret Street Information Delivery Rob Ashmore Financial KPIs for CY 11 – $28 million Information Analytics Clinical Utilisation Review Information Delivery • Hospital, medical, prostheses and ancillary analysis • Hospital, Medical & Prostheses claims leakage savings through audits, claims review, contract compliance, etc • Datamart establishment & data structuring • Contract negotiation support • Demand supply projections/modelling of hospital, medical and ancillary activity • Industry benchmarking • Hospital 2nd tier pricing • HCP collection, QA & submission • Onsite hospital chart to bill and coding audits • Ancillary claims leakage savings through audits & claims reviews, provider de-recognition & prosecution, etc • Ancillary fraud prosecution • Clinical schedule review & updates eg MBS, Prostheses • Medical (SoF) indexing • Negotiations with ADA on dental schedule • AHIA Fraud Committee representation • Comp & Damages claims, debt management and recoveries Bupa Private and Confidential 13 October 2011 • Development of self service tools eg, Futrix, LASAR, hospital contract modelling • Development of scoring programs ie Ultrasound • Develop complex algorithms associated with pattern analysis • Daily ETL from mainframe to SAS datamart Fraud Structure & Bupa Interrelationships Bupa U.K. Bupa International Bupa Australia Board Board Audit Committee Internal Audit CFO CIO Risk & Compliance Legal Director HR CMO Director HBM Business & Clinical Analysis Medicare Australia CEO Director Marketing Director Sales Travel Branches Sales Staff AHPRA Police Hospital & Medical Fraud Prevention Ancillary Fraud Prevention Courts Bupa Ancillary De-recognition Committee Gaol Bupa Private and Confidential 13 October 2011 Staff & Member Fraud Prevention Director Customer Service Claims Membership Contact Centres Director Strategy Bupa Australia - Scale & Scope – Hospital & Ancillary Benefits Discharge Fin Year Specialty Nam e FY10-11 Episode Count (In Total Medical Benefit Prosth Benefit Total Hosp Ben Less Prosth Total Hosp Benefit Private Hospitals Service Fin Year FY10-11 Item Subcategory 1 Services Benefit Paid $355,953,446 $548,836,990 Dental 8,361,898 $425,098,170 $95,164,288 $162,942,922 $258,107,210 Optical 2,389,799 $136,174,409 $25,074,515 $203,551,552 $228,626,067 $60,355,577 $268,038 $123,031,313 $123,299,351 Physio 2,497,784 $74,504,425 2,815,549 $74,122,314 Orthopaedics 86,301 Cardiology 41,208 $69,250,852 General Surgery 68,899 $109,576,570 Obstetrics 33,231 $163,847,822 $192,883,544 6,776 $47,210,499 $13,383,188 $83,158,694 $96,541,882 Chiro & Osteo 40,823 $49,544,239 $6,087,169 $88,303,653 $94,390,822 118,120 $106,846,735 $1,231,991 $91,923,602 $93,155,594 Podiatry 777,867 $27,555,802 Rehabilitation Medic 16,458 $13,834,677 $21,171 $91,514,776 $91,535,947 Remedial Massage 739,287 $16,850,880 General Medicine 60,957 $48,095,031 $1,754,121 $86,304,220 $88,058,341 Ophthalmology Ambulance 49,200 $58,765,691 $18,393,322 $63,622,571 $82,015,894 46,325 $14,427,395 Psychiatry 11,073 $12,884,525 $624,209 $69,298,202 $69,922,411 Pharmacy 520,768 $13,588,799 Gynaecology 40,656 $37,917,996 $3,779,784 $64,903,180 $68,682,964 Acupuncture 438,445 $10,040,189 Respiratory Medicine 26,910 $27,081,213 $341,306 $62,089,718 $62,431,024 ENT 28,228 $27,401,203 $5,082,890 $41,456,103 $46,538,994 Neurology 14,674 $14,264,997 $902,309 $43,007,527 Haematology 24,780 $21,698,033 $627,251 Plastics 16,142 $22,240,215 Medical Oncology 60,837 1,729 Cardiothoracic Urology Gastroenterology Other 76,263 $5,986,282 $43,909,836 Hearing Aid 10,190 $5,396,061 $36,357,344 $36,984,594 $797,095 $31,339,585 $32,136,680 Aids & Appliances 42,504 $5,395,438 $11,490,141 $671,653 $28,733,996 $29,405,649 Psychology 80,647 $4,435,623 $11,069,198 $7,658,366 $18,344,884 $26,003,250 Naturopathy 61,509 $3,977,480 $34,605 $23,046,926 $23,081,531 168,608 $3,714,420 Vascular 3,986 $10,347,251 $4,081,138 $18,396,094 $22,477,233 Speech Therapy 87,193 $2,989,036 Neonatology 4,503 $4,869,019 $11,758 $20,481,242 $20,493,000 Complementary Other 117,393 $2,447,641 Endocrinology 6,548 $7,228,139 $2,270,823 $15,253,463 $17,524,286 20,246 $4,919,538 $47,486 $15,256,563 $15,304,049 Occupational Therapy 50,198 $1,775,829 Dermatology 2,194 $1,359,256 $8,510 $2,261,855 $2,270,365 Dietetics 45,726 $1,399,790 Rheumatology 1,740 $697,545 $6,571 $1,917,460 $1,924,031 8 $33,599 $119 $36,303 $36,422 Orthoptics 1,829 $56,403 3,349 $17,055,892 $4,693,658 $30,756,312 $35,449,970 43,064 $32,262 Total Private Hospitals Public Hospitals 851,085 963,862,934 385,900,881 1,873,243,506 2,259,144,387 114 $9,531 80,038 $69,509,085 $28,391,846 $164,233,779 $192,625,625 Sum m ary 931,123 $1,033,372,018 $414,292,727 $2,037,477,285 $2,451,770,012 Neurosurgery Renal Medicine & Dia Dental&Oral Surgery Immunology Other/Ungrouped Bupa Private and Confidential 13 October 2011 Misc Hypnotherapy Summary 19,311,451 $826,000,699 51 Risk – Players, Products, Systems, Contracts ? • Where you focus depends on where the greatest weaknesses are. • Provider (& their employees) leakage & fraud is the major issue as providers are the “gatekeepers” to the system both in determining services and invoicing • Member & Fund employee leakage & fraud is possible. • The only areas where fraud is possible are those where the member and Fund employee has input into the process • Given that the maximum potential is: • Ancillary – Member & Fund Employee 18% • Medical – Member 23%, Fund Employee 14% • Hospital (Ex EDI and Eclipse) – Member & Fund Employee 0% • The reality is that fraud and leakage is significantly less than the maximum potential shown above • Product – waiting periods, benefit limits, step downs, etc • System leakage is potentially significant depending on the effectiveness of system controls and rules eg field parameters, commercial rules, membership rules, claims assessing • Contracts (Hospital, Medical, Ancillary) – see next slide Bupa Private and Confidential 13 October 2011 52 Contracts & Channels Control Risk Hospital Payment Contracts (Capped ) • Depending on what is bundled into the episodic (ARDRG) capped payment, determines whether there is any value in reviewing the payments • There is no point in examining, for example, ICU certificate classifications, or whether MBS items link to OR bands, or excessive length of stay etc as the price is the price. • 59% of hospital benefits in CY 10 were capped payments Hospital Payment Contracts (Fee for Service ) • As the number of services, length of stay, OR band and ICU classification etc all add to cost, then auditing of these cost inputs are important. • Unbundled ICU benefits are worth $39,000,000, and unbundled OR benefits are worth $118,000,000 Medical Payment Systems • No Gap and Known Gap contracts/agreements stipulate the Fund scheduled price and Gap that is allowed when the provider bills correctly. When a No Gap or Known Gap invoice is submitted, the patient cannot be billed for any other service Ancillary Payment systems • Members First/MemberCare agreements stipulate the schedule fee to be paid as well as mandate the use of HICAPS/iSoft payment systems Bupa Private and Confidential 13 October 2011 BCA Data Mining Methodology Bupa Private and Confidential 13 October 2011 Fraud analytics – Data Mining Supervised Models 1. 40% Transform & Sample 2. 15% Explore 3. 30% Modify Bupa Private and Confidential Unsupervised Models 4. 15% Model 5. 5% Assess 13 October 2011 55 Patterns – Hospitals 1 Potential methods of aberrant claiming in the absence of controls: • Service padding (FFS only) • Upcoding of medical items (DRGs or MBS items in the Australian context) • Contract compliance - invoicing bundled and unbundled payments • Invoicing certificated services for non applicable services • Validity of Fee for Service (FFS) long stay outliers • Prostheses billing for pack when one item only used • Prostheses billing for “duplicates” when covered by manufacturer’s warranty • No informed financial consent by patient (IFC) • Invoicing for duplicate services Bupa Private and Confidential 13 October 2011 56 Patterns – Hospitals 2 Potential methods of aberrant claiming in the absence of controls: • Unnecessary and over long stays e.g. total stay, ICU/CCU stay • Charging more than the contract price • Multiple charging for pharmacy, prostheses, SUO items • Multiple admissions for previous single treatment • Using psychiatric hospitals for rest purposes • Dual admissions (husband and wife) when only one person the patient (borders) • Paying twice for a transferred patient • Paying for weekend leave • Claiming for a hospital benefit under a membership when not a member • Billing for prosthesis “opened in error” or not in patient when they leave the OR Bupa Private and Confidential 13 October 2011 Patterns – Doctors • Potential methods of aberrant claiming in the absence of controls: • Invoicing certificated services for non applicable services (ACC, C, ICU, B) • Cosmetic surgery billed as clinically necessary • Invoicing for No Gap service but invoice member for additional “service” • Invoicing for duplicate services • Inappropriate service categorisation (upcoding) Bupa Private and Confidential 13 October 2011 58 Patterns – Ancillary Providers 1 Potential methods of aberrant claiming in the absence of controls: • Benefit limit (UPI) surfing • Multi ring fraud • Inappropriate service ratios eg service padding • Non clinically necessary eg fissure sealing for a 60 year old • Upcoding eg scale & clean billed as perio, multi surface fillings percentages • Inappropriate age services eg multi focal lenses for a 16 year old • Inappropriate service linkages eg perio and fluoride • Service date shifting to circumvent product rules eg orthodontics & Nov start • Processing services on an unlikely day and/or time of service (ancillary) • “Quoting” searching in EFTPOS system Bupa Private and Confidential 13 October 2011 59 Patterns – Ancillary Providers 2 Potential methods of aberrant claiming in the absence of controls: • Charge higher amount for treatment when Fund product benefits paid at a percentage rate • Reverses and changes items to get a better benefit • Charges for services where the necessary equipment is not owned • Rate of servicing post HICAPS dramatically exceeds pre HICAPS • Prolongs treatment (by not providing necessary treatment) in order to milk the Fund • Bills all members of the family for the same condition up to the annual benefit limit every year • Bills a patient in his rooms when she is in hospital after just having a baby • Bills “Patients” from 3 hours away (from home or work) • Billing for same services provided previously by another provider • Significant number of higher cost services than normal Bupa Private and Confidential 13 October 2011 60 Patterns – Members 1 Potential methods of false claiming in the absence of controls: • False services (medical, ancillary) • Service padding (ancillary) – pressure on providers for no MOOP • Service geographic “hot spots” with high utilisation or high benefit payments (ancillary) • Doctor shopping eg pharmacy • Multi ring fraud (ancillary) • Member receiving a service for a condition they don’t have but that another member of the family has e.g. hearing aid • Same person (agent) making claims for multiple memberships • Large no. of members joining at same time and/or at same address Bupa Private and Confidential 13 October 2011 61 Patterns – Members 2 Potential methods of false claiming in the absence of controls: • False memberships w or w/o bank account “manipulation” (medical, ancillary) • Claims not in keeping with member’s age and claims profile • Claims processed distant from service point (ancillary) • Service provided distant from residence or workplace (ancillary) • Claims lodged at different postcodes • Different claims made through different channels • Accident condition not shown as indemnity (hospital, medical) • Age of new claimant > membership term Bupa Private and Confidential 13 October 2011 62 Patterns – Fund Employees • Potential methods of false claiming in the absence of controls: • Backdating claims (23.5 months) • Processing same services all family members on same or similar days • Creating false memberships • Processing services on an unlikely day and/or time of service (ancillary) • Manually processing a disproportionate percentage of claims from a CPOS provider • Linking many members claims to the same bank account • Changing bank accounts, paying money to oneself and then changing bank account back • False memberships • Bank account “manipulation” Bupa Private and Confidential 13 October 2011 63 Patterns common to Providers, Members, Employees Potential methods of aberrant claiming in the absence of controls: Bupa • Same services for many members of a family on the same or near days • Services not appropriate to age group • Utilising unused aged benefit limits • Padding services • Service on atypical day or time of day • More services than are possible in a day • Benefit limit (UPI) surfing (ancillary) - pressure on providers for no MOOP Private and Confidential 13 October 2011 64 Same services, same day on same family Note same services on same day for all lives on the membership, viz 00012, 00022, 00114, 00121, 00515 Bupa Private and Confidential 13 October 2011 65 Same services, same day on same family • $10,694.20 of dental services from 13 dentists supposedly provided on a Sunday. • Examples of Dr ????? services shown above. Bupa Private and Confidential 13 October 2011 66 Doctor Shopping ? Bupa Private and Confidential 13 October 2011 67