Remark code M134 indicates that the service was performed by a facility or supplier in which the provider has a financial interest. This could potentially raise questions regarding the necessity or appropriateness of the services billed, as there may be a conflict of interest. Healthcare providers should be aware of this when reviewing their Explanation of Benefits (EOB) and claim adjudication to ensure compliance with relevant regulations and payer policies.
Common causes of code M134 are situations where the healthcare provider refers a patient for services or supplies to a facility or supplier in which they have a financial interest. This could include ownership stakes, investment interests, or any other financial relationships that could influence the provider's referral patterns. The code is used to indicate that the claim may be scrutinized for potential violations of laws such as the Stark Law or Anti-Kickback Statute, which are designed to prevent conflicts of interest in healthcare referrals. Causes may also involve inadequate disclosure of the provider's financial interest to the patient or the payer, or failure to comply with the exceptions and safe harbors that allow for certain types of financial interests under specific circumstances.
Ways to mitigate code M134 include implementing a robust conflict of interest policy that requires providers to disclose any financial interests in facilities or suppliers. Regular training should be conducted to ensure that providers understand the implications of referring services to entities in which they have a financial stake. Additionally, internal audits can be performed to monitor compliance with these policies. It's also important to establish clear documentation practices that demonstrate the medical necessity of services and the rationale for choosing specific facilities or suppliers, independent of any financial considerations. By doing so, healthcare providers can ensure that referrals are made based on patient care needs rather than financial interests, thus reducing the likelihood of encountering code M134.
The steps to address code M134 involve a thorough review of the claim to ensure that the services billed were indeed performed by a facility or supplier where there is a financial interest disclosed by the provider. If this is accurate, confirm that all necessary disclosures regarding the provider's financial interest have been made in accordance with applicable laws and regulations. If the claim was submitted incorrectly, amend the billing information to reflect the appropriate facility or supplier without a financial interest and resubmit the claim. Additionally, it may be necessary to review internal processes to prevent similar issues in future billing cycles, including implementing checks for provider financial interests during the charge capture and claims submission processes.