OIG Sounds the Alarm — and RAC Auditors Follow: What Every Vascular Physician Needs to Know Right Now

Federal enforcement is now targeting peripheral vascular procedures, selective catheter placement, angiograms, and vascular embolizations simultaneously. Here is what changed, what is at stake, and what to do.

By Elina Sabilova, CPC, CFPC, CPMA, Billing Department, WCH Service Bureau

The Enforcement Landscape Has Shifted — Fast

Vascular specialists and interventional radiologists who bill under Medicare Part B are now operating in one of the most scrutinized billing environments in recent memory. Within weeks, two separate federal enforcement developments have converged on the same specialty — creating compounding audit exposure for practices that perform office-based peripheral vascular procedures, selective catheter placements, angiograms, and vascular embolizations.

Understanding both developments — and how they interact — is essential for every physician in this space.

Part 1: The OIG Report on Peripheral Vascular Procedures

Background

On May 5, 2026, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released a landmark report: “Utilization Trends and Medicare Part B Billing for Office-Based Peripheral Vascular Procedures Raise Questions About Program Integrity” (Report OEI-01-24-00250).

Medicare Part B paid over $1 billion in 2022 for peripheral vascular procedures — angioplasty, stenting, and atherectomy — performed to treat narrowed or blocked arteries causing leg pain. For years, clinical stakeholders have raised concerns about the potential overuse of these procedures, particularly when established guidelines recommend attempting conservative treatments before moving to intervention.

What has amplified those concerns is the financial incentive structure: Medicare reimburses physicians significantly more for procedures performed in office-based laboratories (OBLs) compared to hospital outpatient departments. This differential has driven a major shift in care setting — and has drawn intense scrutiny from federal oversight agencies.

Key Findings (2019–2023)

Dramatic shift to OBLs. While overall procedure volumes and total Medicare Part B payments for peripheral vascular procedures declined between 2019 and 2023, the site of care shifted substantially toward OBLs — where physician reimbursement is higher and regulatory oversight is more limited.

High rates of controversial procedures in OBLs. In 2023, despite ongoing clinical debate about their risk-benefit profile:

• 75% of atherectomy procedures were performed in OBLs
• 47% of tibial artery procedures were performed in OBLs

$105 million in potentially unnecessary procedures. Of Medicare payments made to OBL physicians for peripheral vascular procedures, the OIG identified approximately $105 million that may indicate billing for medically unnecessary services. Critically, just 26 physicians accounted for 61% of these concerning payments.

OIG’s Formal Recommendations — and CMS’s Response

The OIG issued two recommendations to the Centers for Medicare & Medicaid Services (CMS), and CMS concurred with both:

• Recommendation 1: Monitor billing to identify peripheral vascular procedures that may be medically unnecessary, which may indicate fraud, waste, or abuse.
• Recommendation 2: Follow up directly with the specific physicians OIG identified with concerning billing patterns.

CMS’s agreement with both recommendations is not bureaucratic formality. It is a commitment to active enforcement. Physicians with OBL-based vascular practices should treat this as a direct and personal warning.

Part 2: RAC Auditors Target Selective Catheter Placement, Angiograms, and Vascular Embolizations

Separately from the OIG report, Recovery Audit Contractors (RAC) have identified selective catheter placement as a new priority audit category. This targets a broader range of vascular interventional services — including diagnostic angiograms and vascular embolizations — with direct focus on two CPT codes:

CPT 36247 — Selective catheter placement, arterial system; third order or more selective thoracic or branching vessel

CPT 37229 — Endovascular revascularization, open or percutaneous, tibial/peroneal artery, with transluminal angioplasty

RAC auditors reviewing these codes will focus on:

• Medical necessity: Is there clinical documentation supporting the need for the procedure at the level billed?
• Level of selectivity: For CPT 36247, does the operative record and imaging confirm third-order or higher selectivity — or was a lower-selectivity code more appropriate?
• Bundling compliance: Were CPT 36247 and 37229 correctly billed in conjunction with other interventional procedure codes, or were services inappropriately unbundled?
• Documentation of clinical indication: For angiograms and embolizations, is the clinical indication clearly established and supported throughout the medical record?

Part 3: Why These Two Developments Must Be Understood Together

These are not separate issues. They represent a coordinated intensification of federal oversight across the full spectrum of vascular interventional billing.

CPT 36247 (selective catheter placement) and CPT 37229 (tibial endovascular revascularization) are frequently billed alongside the peripheral vascular procedures already flagged by OIG — angioplasty, stenting, and atherectomy. A practice that bills this combination of services faces scrutiny on multiple fronts simultaneously: OIG-flagged utilization patterns, RAC claim-level audits, and potential False Claims Act exposure.

The enforcement consequences are already real. Just days after the OIG report was released, a vascular practice agreed to pay over $6.73 million to settle False Claims Act allegations related to unnecessary vascular interventional procedures. This is not a hypothetical future risk — it is the present reality.

What to Expect: The Audit Mechanisms Now in Play

Practices billing peripheral vascular procedures and/or selective catheter placements under Medicare should anticipate:

• Pre-payment and post-payment audits from RAC, ZPIC, MAC, and OIG contractors
• Individual physician targeting — OIG has already compiled a list of concerning billers and handed it to CMS
• Documentation-focused reviews — auditors will look specifically for evidence that conservative treatment was attempted before intervention, that catheter selectivity is supported in the record, and that medical necessity is documented at every step
• Pattern analysis — utilization ratios, procedure mix, and frequency compared to peer benchmarks will all be examined

How WCH Service Bureau Can Help: Proactive Pre-Audit Compliance Review

At WCH Service Bureau, we understand that the overwhelming majority of vascular physicians perform these procedures with genuine clinical intent. But intent is not a defense when federal auditors arrive with a targeted list and a data-driven case.

We are inviting vascular specialists, interventional radiologists, and OBL operators — particularly those billing peripheral vascular procedures, selective catheter placements, angiograms, or vascular embolizations under Medicare — to work with us on a proactive pre-audit compliance review covering all currently targeted procedure categories.

Our Pre-Audit Service Includes:

• Deep-dive review of your claims for CPT codes associated with angioplasty, stenting, atherectomy, CPT 36247, CPT 37229, angiograms, and embolizations against current CMS coverage criteria and LCD requirements
• Medical necessity documentation assessment — verifying that conservative treatment was attempted and properly documented prior to intervention
• Catheter selectivity audit — confirming that the level of selectivity billed for CPT 36247 is supported by operative and imaging records
• Bundling and unbundling review across co-billed procedure codes
• Identification of high-risk billing patterns that mirror OIG’s flagged criteria and RAC’s audit targets
• Corrective Action Plan (CAP) development if issues are identified — so you control the outcome, not the auditor
• Staff education and documentation improvement protocols to prevent future exposure

Free Sample Audit — See Exactly Where You Stand

Not sure what to expect? We will show you — at no cost and with no obligation. Send us 2–3 patient records from your peripheral vascular or catheter placement procedures, and our compliance specialists will conduct a complimentary audit. You will receive a clear picture of how your documentation and billing patterns compare to current CMS medical necessity criteria, OIG’s flagged indicators, and RAC’s active audit targets.

Act Now — Before the Auditors Do

The OIG has identified the problem. CMS has agreed to act. RAC auditors have expanded their target list. Enforcement is already underway.

The question for every vascular specialist and interventional radiologist billing under Medicare is simple: Will you be reactive — or proactive?

A pre-audit review is not an admission of wrongdoing. It is the most powerful tool available to protect your practice before federal scrutiny reaches your door. Practices that identify and correct issues proactively face a dramatically different — and far more favorable — outcome than those caught off-guard by an audit.

Contact WCH Service Bureau today to schedule your confidential pre-audit compliance consultation. We serve vascular physicians, interventional radiologists, OBL operators, and multi-specialty groups nationwide.

Source: OIG Report OEI-01-24-00250, issued May 5, 2026. Available at oig.hhs.gov. This article is provided for informational purposes and does not constitute legal advice.