Articles Posted in Compliance

As many already know, when a review contractor (e.g., Recovery Audit Contractors (“RACs”), Medicare Administrative Contractors (“MACs”), the Comprehensive Error Rate Testing (“CERT”) contractor, the Program Error Rate Measurement (“PERM”) contractor, and Zone Program Integrity Contractors (“ZPIC”)) identifies an improper payment, the review contractor requests medical documentation from the provider or supplier to ensure the […]

On September 14, 2011, the Centers for Medicare and Medicaid Services (“CMS”) published in the Federal Register a proposed rule amending the Clinical Laboratory Improvement Amendments of 1988 (“CLIA”) and the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) to specify that, upon request, a patient may gain access to his/her completed test reports […]

The Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) has issued its monthly Recovery Act Oversight report for July 2011. The report revealed what many already know: audits and investigations are have increased considerably since 2009, the year the American Recovery and Reinvestment Act of 2009 (“Recovery Act”) was signed into […]

Wisconsin Physician Services (WPS)–the Part B Medicare Administrative Contractor (MAC) for Iowa, Kansas, Missouri and Nebraska and the Legacy Medicare Carrier for Michigan, Illinois, Wisconsin and Minnesota–regularly conducts Service-Specific Probes (Probes) “to validate potential systematic problems with billing, utilization, and or/documentation of a specific service.” In a recent Probe, 99213–the billing code for established patient […]

On September 1, 2011, the Department of Justice, the Department of Health and Human Services (HHS), the FBI and the HHS Office of Inspector General (HHS-OIG) jointly announced that eighteen individuals have been charged in the Eastern District of Michigan for their participation in a series of separate Medicare fraud schemes involving home health and […]

In two reports posted August 30, 2011, the Department of Health and Human Services, Office of Inspector General (OIG) announced that many Independent Diagnostic Testing Facilities (IDTFs) in Miami and Los Angeles failed to comply with selected Medicare standards after unannounced site visits in May and June 2010. An IDTF offers diagnostic services and is […]

Statistics recently released by the Transactional Records Access Clearinghouse (TRAC), a Syracuse University Research organization, show a marked increase in federal health care fraud prosecutions. The statistics show 903 federal prosecutions for health care fraud through the first eight months of 2011, compared to 731 such prosecutions for all of 2010. In addition to the […]

A common reason for claim denials through the Comprehensive Error Testing (“CERT”) program and the medical review process is a lack of provider signatures on orders and medical documentation. Medicare requires that services provided and/or ordered be authenticated by the author. The method of authentication must be a handwritten or electronic signature. Stamped signatures are […]

In its over-300-page complaint filed on 8/19/2011, GEICO General Insurance Company, et. al (hereinafter referred to as “GEICO”) asserts that the 32 defendants named in this case–13 physicians, 18 entities, and 1 entity owner– (“Defendants”) defrauded GEICO in an amount in excess of $12.1 million under New York’s No-Fault Insurance law. GEICO also seeks to […]

The Health Information Technology for Economic and Clinical Health Act (“HITECH”) requires the Office of Civil Rights (“OCR”) to conduct periodic audits of covered entities in connection with complying with the privacy and security requirements set forth in Health Insurance Portability and Accountability Act (“HIPAA”). In June, the OCR awarded KPMG, LLP (the “Contractor”) a […]

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