Medicare, Medicaid & Private Payor Updates

EHR Cloning Practices Can Lead to Medicare Audits

(December 26, 2013): The Department of Health and Human Services (HHS) has long viewed the adoption of Electronic Health Records (EHRs) as a way to better coordinate care, improve the quality of care, reduce unnecessary paperwork, and eliminate duplicative medical testing. Based, at least in part, on these beliefs, Congress authorized incentive payments to encourage […]

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Improper Medicare Payments Are Still Being Made for Deceased Beneficiaries

(November 20, 2013): While most health care providers and suppliers are diligent in their efforts to ensure that Medicare services are submitted appropriately, mistakes and other improper billings still take place. Two areas of continuing concern involve providers and / or suppliers who submit fraudulent claims to Medicare seeking reimbursement on behalf of deceased beneficiaries

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Wake Up Sleep Labs! OIG is Concered About Questionable Billing Practices

(October 24, 2013): Over the next year, sleep lab / sleep medicine practices and clinics should expect to receive increased scrutiny from both the Department of Health and Human Services, Office of Inspector General (OIG) and from program integrity contractors working for the Centers for Medicare and Medicaid Services (CMS). These contractors may include Zone

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Should You be Concerned About a Consultant Qui Tam?

(October 16, 2013): Healthcare providers should be on guard – a new type of whistleblower may be an individual you would least expect. Recently, the Department of Justice (DOJ) entered into a multi-million dollar settlement agreement with a Florida-based healthcare provider based on claims that the provider submitted false claims to various Federal and State

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Complying with an Individual’s Request to Restrict the Submission of PHI to Insurance

(October 3, 2013): The HIPAA Omnibus Rule (Omnibus Rule) is well over 100 pages long. When considered in the context of existing HIPAA and HITECH, health care providers are often it difficult to apply the provisions of the Omnibus Rule to privacy situations that are commonly arising in a physician’s practice. One such situation is

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Texas Medical Board Complaints are Serious Business!

(September 20, 2013): Like other physicians around the country, Texas physicians are currently facing increasing pressures to ensure that their medical necessity determinations, coverage assessments, documentation, coding and billing activities meet both Medicare’s requirements and those of private payors. While their duties and responsibilities have continued to increase, reimbursement rates have steadily fallen. Notably, Texas

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Are Your Outpatient Therapy Claims Ready For Manual Medical Review by a Medicare RAC?

(September 5, 2013): Since April 1, 2013, Medicare’s Recovery Audit Contractors (RACs) have been conducting manual medical reviews for all Medicare Part B therapy services that exceed a $3,700 threshold. There has been some early confusion on behalf of outpatient therapy providers, and the Centers for Medicare and Medicaid (CMS) have been bombarded with questions

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Prepayment Reviews and Postpayment Audits are Increasing in Frequency — New Guidance has Been Issued to ZPICs

(September 3, 2013): On August 21, 2013, the Centers for Medicare & Medicaid Services (CMS) released “Transmittal 485/Change Request 8079”. This transmittal imposes an obligation on Zone Program Integrity Contractors (ZPICs) and Program Safeguard Contractors (PSCs) to notify a health care provider prior to placing them on the provider on prepayment or postpayment review. There

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Strategic Health Solutions has Initiated an E/M Claims Audit of 99214 and 99215

(August 15, 2013): Over the last few months, Strategic Health Solutions, LLC, a Supplemental Medical Review Contractor, appears to have significantly stepped up its post-payment audits of physicians and non-physician practitioners billing high level Evaluation and Management (E/M) codes. Strategic Health Solutions’ current audit push appears to be focused on E/M services provided to established

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When Did You Last Review Your Private Payor Contracts? You Need to Analyze Before You Sign!

(August 14, 2013): In today’s reimbursement environment, solo physicians and physician practice groups are witnessing a steady decline in reimbursement rates. Unfortunately, their overhead costs and obligations due to the imposition of Electronic Medical Records, HIPAA Privacy, OSHA and a litany of other regulatory requirements are making more and more difficult to remain profitable each

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