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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 and enforcement of the HIPAA Privacy Rule. The OIG recommendation is clear in the September 2015 executive summary, “OCR Should Strengthen Its Oversight of Covered

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

Are You Aware of the Whistleblower Provisions of the False Claim Act ?

The whistleblower provisions of the False Claims Act have lead to several newsworthy cases in recent years. Just a few days ago, the Justice Department announced that KMART Corporation (Kmart) will pay $1.4 Million to resolve False Claims Act allegations for knowingly providing coupons to Medicare beneficiaries to waive or reduce co-pays for purchasing more

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 from an immediately related provider, any of their associates or their professional corporations. As part of Stark I in 1989, self-referrals for clinical laboratory services

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

Are you a Meaningful User of the Future?

Since the Electronic Health Records (EHR) incentive program known as Meaningful Use began in 2011, the healthcare community has felt its impact and attempted to meet the increasing obligations. A new language has been created with an alphabet soup of acronyms. Physicians voice concerns that complying with Meaningful Use competes with attention on patients and

$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

CMS Just Announced New Provider Enrollment Provisions

As of December 3, 2014, new safeguards have been added to the CMS provider enrollment policies. CMS continues to focus on prevention of Medicare fraud, waste and abuse as part of their comprehensive program integrity plan. Reportedly, 25,000 providers have already been excluded from participation and may no longer be able to re-enroll. Use of

Are You Billing for Home Care Visits?

Physician home visits are under scrutiny by CMS for any possible fraud. In 2012, Medicare paid home care service providers about $236 million. As the population of Medicare age recipients increases it seems likely that the need for home care services will also increase. There are many benefits to providing home care services such as

Have You Reviewed the OIG 2015 Workplan?

The 2015 Workplan of the Office of the Inspector General highlights important areas for providers including medical necessity of services billed, payment review, exclusions, and incentive payments. Determination of the medical necessity of services billed is a primary focus of the Workplan. As stated in the Social Security Act, Medicare will not pay for items