The Office of Inspector General (“OIG”) today published a report regarding overpayments identified made to inpatient rehabilitation facilities (“IRFs”) from 2004 through 2007. According to the report, of the claims reviewed by the OIG, the vast majority (i.e., 213 out of 220) of transfers from an IRF to another facility were improperly coded as discharges. […]
It looks like the days of “voluntary” compliance programs for the health care industry are coming to an end. Specifically, Section 6401(a)(7) of the Patient Protection and Affordable Care Act (“PPACA” or the “health care reform bill”) included provisions mandating compliance programs as part of the Medicare enrollment process. According to the health care reform […]
On June 14, 2010, CMS published a report entitled, “The Medicare Recovery Audit Contractor (RAC) Program: Update to the Evaluation of the 3-Year Demonstration Program.” This report contains statistics through March 9, 2010 and includes updated appeals data. The new report reveals a much lower number of appeals than had previously been reflected. Specifically, the […]
On June 9, 2010, the Office of Inspector General (OIG) published a report regarding inpatient rehabilitation facility (IRF) payments made in 2006 and 2007. According to this report, over half of the claims reviewed (i.e., 113 out of 200 claims) resulted in overpayments, because the providers failed to submit patient assessment instruments within the requisite […]
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 I: Reversal and Correction to […]
Medicare requires that services provided/ordered must be authenticated by the author with either a hand written or electronic signature (stamps are not acceptable), although there are a few exceptions: (1) facsimiles of original written/electronic signatures are acceptable for the certification of terminal illness for hospice; (2) some orders do not need to be signed, for […]
Centers for Medicare and Medicaid Services (“CMS”) reported yesterday that it realizes that fiscal intermediaries haven’t been providing sufficient detail on remittance advices (RAs) when recouping overpayments identified by RACs to allow providers to track and update their financial records. In response to that complaint, CMS issued CR 6870 and the corresponding MLN Matters 6870, […]
The New York state attorney general’s office announced yesterday that it recovered more than $283 million and obtained a record of 148 Medicaid fraud convictions in 2009. This information is detailed in an Annual Report submitted to the Secretary of the U.S. Department of Health and Human Services. The report highlights the cases, settlements, and […]
In a recent development for the anesthesia community, HealthDataInsights (“HDI”), the RAC for Region D, removed the anesthesia care package issue from its approved issues list. In January of 2010, the RAC vendor posted the following issue: Under NCCI Edit rules, the anesthesia care package consists of preoperative evaluation, standard preparation and monitoring services, administration […]
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 because of the program’s cost-effectiveness, […]
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