Jumpstart Your Compliance Program

The beginning of the New Year is a popular time for new initiatives. Many healthcare organizations are looking for ways to improve quality and reduce risk. A compliance program is an effective way to detect, deter and prevent wrongdoing in the healthcare setting and an ongoing system assures conformity with governing laws and regulations. An

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.” To read the full contents of the Yates Memo, click here. Essentially, the Yates Memo shifts the DOJ’s approach to fighting corporate fraud and misconduct

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 improvements to the system that would promote efficiency and efficacy within the limits of the health care laws.   Although OIG oversight includes programs such as

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 claims against federal health care programs such as Medicare and Medicaid.  Most healthcare providers are aware of significant civil liability due to recent enforcement. However,

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, any re-certifications and care plan supervision. However, only physicians can bill for initial certification and re-certification and only one physician can bill per month. The

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 clients in preparing the front office. Here are some recommendations to ensure that proper steps are taken: Immediately contact your supervisor, manager and/or Compliance Officer

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 perceived satisfaction may not be a result of receiving the best quality of care and in some cases may be due to inappropriate or wasteful

$22 M of Potential Fraud, Waste and Abuse Discovered in 2012 Medicare Ophthalmology Claims

In 2012, approximately 49 million Medicare claims were related to screening, diagnosis or treatment of cataracts, wet acute macular degeneration and/or glaucoma. Medicare paid approximately $3.5 billion for these particular services. Review of the data using 4 National Coverage Requirements found $14 million in potentially inappropriate payments and according to 2 Local Coverage Requirements an