Having a compliance program in place is a start but having an effective compliance program is the goal. Proactively assessing the effectiveness of one’s own compliance program is better than…
Deadline for Breach Reporting Coming Soon
As the end of the year approaches, keep in mind that all breaches of unsecured protected health information involving less than 500 individuals must be reported to the Secretary at…
Beware of Individual Liability: Yates Memo
On September 9, 2015, the Department of Justice (DOJ) Deputy Attorney General Sally Yates released a policy memorandum, titled “Individual Accountability for Corporate Wrongdoing,” also known as the “Yates Memo.”…
OIG WORKPLAN 2016
The Office of the Inspector General (OIG) is responsible for protecting the integrity of the programs in Health and Human Services against fraud, waste and abuse as well as recommending…
Overview of a Corporate Integrity Agreement (CIA)
Health care fraud recoveries for fiscal years 2009- 2014 exceeded previous records with five straight years of more than $2 billion in annual recovery from cases involving fraud and false…
Are You Prepared for the HIPAA Phase 2 Audits?
After reviewing the HIPAA Privacy case investigations from 2009-2011, the Office of the Inspector General sent a strong message to the Office of Civil Rights in regard to the administration…
Billing Care Plan Oversight Risks
Care Plan Oversight describes the physician or other healthcare professional’s supervision of patients in hospice, nursing facilities or those receiving care through home health agencies. CPO reimbursement covers initial certification,…
Complying with Stark Law: Can you bill Medicare when treating your family members?
The treatment of family members falls under General Exclusions from Coverage under Medicare. No payment will be made for items or services for a family member when the charge is…
How would your staff react to an auditor or investigator?
Audits and investigations are stressful events either with or without prior notice. Medical staff should be prepared for an unannounced visit. First Healthcare Compliance provides a sample policy that assists…
Avoiding Overutilization vs. Patient Satisfaction: What’s a provider to do?
An increasingly important issue for many providers is the dilemma of providing care that is satisfactory to the patient while avoiding overutilization and its effect on reimbursement. Unfortunately, the patient’s…