In 2009, Medicare spent nearly one fifth of its Part B payments on Evaluation and Management (E&M) Services. Providers are responsible for ensuring proper coding when submitting their claims. The OIG will review the E&M claims that have been submitted to determine if coding patterns vary by provider. Furthermore, the…
The OIG will review hospice services in connection with nursing facilities. According to the Work Plan, “in a recent report, OIG found that 82 percent of hospice claims for beneficiaries in nursing facilities did not meet Medicare coverage requirements.” As a result, the OIG will look closely to nursing facilities…
The OIG will examine a number of Home Health Agency (HHA) issues, a number of which are provided in this entry. The OIG will scrutinize payments made under Part B’s HHA prospective payments. The Social Security Act requires that all services provided under a plan of care of an HHA…
The OIG will review a number of payment systems including, but not limited to, capital payments, the provider-based status payments, the inpatient prospective payment system, excessive Medicare payments, Medicare disproportionate share payments, duplicate graduate medical education payments, payments for diagnostic radiology services in emergency departments, and compliance with the Medicare…
In an audit of Michigan’s Medicaid program, the Office of Inspector General (OIG) found that Michigan’s Medicaid agency did not report on the CMS-64 $3 million in over payments–a direct violation of Section 1903(d)(2) of the Social Security Act (Act). Of that $3 million not reported, $2,198,100 was the federal…
On October 4, 2010, the OIG released its Work Plan for the FY of 2011. Throughout the week, we will be posting on various aspects of the Work Plan pertinent to our clients and our readers in the following areas: • Hospitals • Home Health Agencies • Hospices • Evaluation…
On September 30, 2010, the Arkansas Supreme Court held that Baptist Health, a private, charitable, nonprofit corporation, may not impose an Economic Conflict of Interest Policy (Policy). In this case, “the Policy mandates the denial of initial and renewed professional staff appointments or clinical privileges at any Baptist hospital to…
Novartis Pharmaceuticals, a US subsidiary of a Swiss pharmaceutical group Novartis, settled with the US Department of Justice (DOJ) for $420 million for allegations of the off-label promotion of Trileptal, submitting false claims because of the unlawful marketing, and paying kickbacks to health care professionals inducing them to prescribe Trileptal…
On September 28, the Office of Inspector General (OIG) posted Advisory Opinion 10-20 in which it analyzed another pre-authorization arrangement. This is the OIG’s third Advisory Opinion issued this year that favorably reviews the provision of free pre-authorization services to referral sources (please visit our September 9 and May 14…
Pursuant to our September 11, 2010 blog entry, the FTC is to hold a day-long workshop entitled “Workshop Regarding Accountable Care Organizations and Implications Regarding Antitrust, Physician Self-Referral, Anti-Kickback and Civil Monetary Penalty Laws.” According to the workshop’s website, those who are unable to attend the Baltimore workshop may listen…