Last month, we published a post regarding the new protocols that CMS is requiring RACs to use on Remittance Advice (RAs) when identifying and recouping overpayments. CMS has also issued the additional Transmittal 659, which sets forth the two-step process of utilizing RAs to report amounts to be recovered. Step…
HLP founding partner Robert S. Iwrey, Esq. was quoted in a “Patient Records Legal Primer” article in the award-winning, national publication Physicians Practice. You can read about how to ensure that your record-keeping is well managed by clicking here.
It looks like the days of “voluntary” compliance programs are coming to a close. As we discussed in a recent blog, the health care reform bill contained provisions mandating compliance programs. New York providers receiving Medicaid funds have already experienced mandatory compliance obligations as a result of the New York…
On May 7, 2010, CMS promulgated Transmittal 697 to align the requirements governing the timely filing limits (for submitting claims for Medicare Fee-for-Service (“FFS”) reimbursement) with the requirements set forth in the Patient Protection and Affordable Care Act (the “PPACA”). By way of background, a service provider or supplier formerly…
As reported in the May 14th HLP blog, the Departments of Justice (DOJ) and Health and Human Services (HHS) recently released the Health Care Fraud and Abuse Control Program (HCFAC) Annual Report for Fiscal Year 2009, which reflects that $2.51 billion was deposited to the Medicare Trust Fund in 2009,…
On May 6, 2010 the Office of Inspector General (the “OIG”) posted Advisory Opinion 10-04, which approved a program conducted by several imaging centers to provide free pre-authorization services to patients and referring physicians (the “Pre-Authorization Arrangement”). This approval was somewhat unexpected in light of the OIG’s prior issuance of…
This month, the Office of Inspector General published its report of the activities and results of the Health Care Fraud and Abuse Control Program for 2009. A few highlights from the report include: 1014 new criminal health care investigations opened, 583 fraud-related convictions concluded, and $1.63 billion in judgments and…
Centers for Medicare and Medicaid published an interim final rule on May 5, 2010, that begins implementation of certain provisions of the Patient Protection and Affordable Care Act (PPACA) relating to Medicare and Medicaid program integrity. The regulations, with a comment period ending on July 6, 2010 (the effective date…
The Office of the Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) issued a report this month showing that program safeguard contractors (“PSCs”) have not resulted in significant recoveries to the Medicare program. PSCs are intended to detect and deter fraud and abuse in Medicare, by…
Compliance continues to be a hot topic given the continued increase in enforcement, audits and other aspects of health care reform. On May 7, 2010, the Office of Inspector General (OIG) posted on its website an excerpt from a keynote address that the Inspector General for the Department of Health…