Health Law

Published on: May 11, 2011 | by The Health Law Partners

Erroneous Medicare Payments for Radiology Services in Hospital Emergency Departments Exceed the $30 Million Mark in 2008

Based on a recent report from the Office of Inspector General (“OIG”), Medicare permitted $38 million of improper claims for interpretation and reports of radiology services based on insufficient documentation in hospital emergency departments in 2008. This includes a 19 percent erroneous allowance of claims for interpretation and reports for magnetic resonance imaging (“MRI”) and […]

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Published on: May 10, 2011 | by The Health Law Partners

CMS’ RAC Recoveries Accelerate

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 […]

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Published on: May 9, 2011 | by The Health Law Partners

Hospice Wage Index to Rise in FY 2012 under CMS’ Proposed Rule

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 […]

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Published on: May 9, 2011 | by The Health Law Partners

CMS Issues Final Rule for Credentialing for Telemedicine Services

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, […]

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Published on: May 1, 2011 | by The Health Law Partners

Signature Requirements Fact Sheet Now Available

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 […]

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Published on: March 15, 2011 | by The Health Law Partners

ACO Regulations May Finally Be Near

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 […]

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Published on: February 8, 2011 | by The Health Law Partners

Medicare Part B Contractor Denies 96% of Neurology Claims in Recent Probe

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 […]

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Published on: February 3, 2011 | by The Health Law Partners

Facet Joint Injections Considered for RAC Review

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 […]

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Published on: February 2, 2011 | by The Health Law Partners

Report Compares For-Profit Hospice with Not-For Profit Hospice Patient Populations

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 […]

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Published on: January 28, 2011 | by The Health Law Partners

CMS Issues Revised Interpretive Guidelines for Hospital Conditions of Participation – Anesthesia Providers Affected

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, […]

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