The Centers for Medicare and Medicaid Services (“CMS”) overpayment recovery through its Recovery Audit Contractor (“RAC”) program is on the rise. CMS recovered in excess of $313 million in Medicare overpayments since October 2009, and almost half of that amount ($162 million) was collected during the first three months of 2011. In comparison, only $75.8 […]
The Centers for Medicare & Medicaid Services (“CMS”) recently proposed a rule regarding the hospice wage index for the fiscal year (“FY”) 2012 (“Proposed Rule”). The rule would result in a 2.3 percent increase in Medicare payments to hospices for FY 2012 and implement a new quality reporting system as required by the Affordable Care […]
On May 5, the Centers for Medicare and Medicaid Services (CMS) published in the Federal Register its final rule for telemedicine credentialing and privileging for hospitals and critical access hospitals (CAHs). Beginning July 5, 2011, hospitals and CAHs, will have the option of proxy credentialing distant-site physicians and practitioners pursuant to a written agreement. Currently, […]
Our attorneys are seeing an increase in Medicare claim denials resulting from the lack of valid practitioner signatures. A new publication from the Medicare Learning Network® titled “Comprehensive Error Rate Testing (CERT) Signature Requirements” provides the guidance necessary to avoid such denials. The fact sheet aims to educate health care providers on signature and supporting […]
Since the signing of the Patient Protection and Affordable Care Act (PPACA) last year, there has been considerable attention and interest within the industry towards accountable care organizations (ACOs). Accompanying this focus has been a series of questions regarding the compositional requirements, as well as the operational and structural opportunities to be afforded to (and […]
Wisconsin Physician Services (“WPS”), the Medicare Part B Carrier for providers in Michigan, Illinois, Minnesota and Wisconsin, recently conducted a service-specific probe review of Current Procedural Terminology (“CPT”) 99233 billed by neurology providers. WPS found that only 4 percent of billed claims were payable. 96 percent were denied or down-coded. CPT 99233 is a hospital […]
The recovery audit contractor (“RAC”) for Region B covering the Midwestern states, CGI Federal, Inc., is requesting additional documentation from providers regarding facet joint injections without reported imaging guidance (CPT codes 64470-64476). The requests for additional documentation acknowledge that CMS has not yet approved this issue for complex review and further acknowledge that the RAC […]
A report published in the February 2, 2011 edition of the Journal of the American Medical Association, compared the patient diagnoses, length of stay, and location of service for hospice patients receiving care from for-profit and not-for-profit hospices. The researchers found that for-profit hospices had a higher percentage of patients with non-cancer primary diagnoses, and […]
CMS has issued revised Interpretive Guidelines for the Hospital Conditions of Participation. The revised Interpretive Guidelines, which are effective immediately, contain significant changes affecting anesthesia providers, including the following: • Labor Epidurals. CMS removed language exempting labor epidurals from the physician supervision requirements. The revised Interpretive Guidelines note that, “there is often no bright line, […]
During the Recovery Audit Contractor (“RAC”) demonstration program, a significant number of the claims denied were denied for the reason that an inpatient hospital admission was not medically necessary. The RACs regularly based these denials not upon published Medicare guidance, but based upon the criteria of private companies, such as InterQual. In an effort to […]
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