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Get Ready: The RAC Program Soon May Be Expanding

As Medicare providers and suppliers are acutely aware, the Centers for Medicare and Medicaid Services (“CMS”) has determined that the use of Recovery Audit Contractors (“RACs”) is a “cost-effective” way to identify and correct improper payments, in part as a result of the contingency-fee-based structure of using these auditors. Primarily…

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Joint Commission Approves Revised Medical Staff Bylaws Standard

On March 15, 2010, the Joint Commission announced revisions to Medical Staff Standard MS.01.01.01 (formerly known as MS.1.20). The revisions are based on the unanimous recommendations of an 18-member expert task force representing the American College of Physicians, American College of Surgeons, American Dental Association, American Hospital Association, American Medical…

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OIG Releases Compendium of Unimplemented Recommendations

Last week, the OIG released it’s Compendium of Unimplemented Recommendations that “consolidates significant unimplemented monetary and nonmonetary recommendations addressed to the Department of Health & Human Services (HHS) to provide information to interested parties about outstanding recommendations….” While these have not been implemented, it is something we want our clients…

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Office of Civil Rights Hints it May Delay Enforcement of Security Provisions in HITECH Act

While the HITECH Act technically went into effect last month, on February 17, 2010, HHS’s Office of Civil Rights (“OCR”) has yet to issue guidance and regulations about the implementation of new privacy and security requirements contained in the HITECH Act. Because of this failure, OCR has been hinting that…

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HHS Announces Additional $162 Million to Promote Meaningful Use of Health Information Technology

HHS announced that it would “provide approximately $162 million to 16 states and qualified designated entities (SDEs) to facilitate non-proprietary health information exchange that adheres to national standards.” Those states receiving part of that $162 million are Florida, Maryland, New Jersey, South Carolina, Iowa, Idaho, North Dakota, Alaska, Nebraska, South…

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OIG Cracks Down First Months of 2010

The Office of Inspector General (OIG) has continued to indict, prosecute, and convict members of the healthcare community for allegedly violating the Civil Monetary Penalty (CMP) statue and the False Claims statute. Some notable prosecutions are below: – On February 2, 2010, Maria Aloise, the president and owner of Atenas…