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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

What Should You Do After Discovering a Billing Error?

Just correct the problem and you will be compliant? No, but this is the first step in the right direction. According to the HHS in “A Roadmap for New Physicians – Avoiding Medicare and Medicaid Fraud and Abuse,” the following steps should be taken: Immediately cease filing the problematic bills Seek knowledgeable legal counsel Determine

Improper Payments for Evaluation & Management Services Cost Medicare Billions in 2010

According to the Office of the Inspector General’s report for 2010, Evaluation and Management services accounted for 30% of Medicare Part B payments, a total cost of $32.3 billion.  However, 55% of these 370 million claims were coded incorrectly and/or lacked appropriate documentation.  These claims correlated to $6.7 billion in improper Medicare payments. 26% of