March 2010 Archives

March 30, 2010

CMS's Deletion of "Purchased Interpretations" Causes Problems for Certain Out-of State teleradiology arrangements: Imaging Centers Billing for out-of-State interpretations can Expect Claim Denials

Effective March 15, 2010, pursuant to CMS's update to the Medicare Claims Processing Manual addressing "Payment to Physician or Other Supplier for Diagnostic Tests Subject to the Anti-Markup Payment Limitation", among other actions, The Centers for Medicare and Medicaid Services ("CMS") has effectively eliminated an Independent Diagnostic Testing Facility's ("IDTF's") or radiology group's ability to bill its local carrier (the "MAC") for interpretations performed by out-of-state physicians (the "CMS Change Request"). Rather, by operation of these Medicare changes and Medicare's claims processing system, these imaging suppliers must now either take reassignment and bill the MAC in the interpreting physician's jurisdiction (if and only if they are able to establish a practice location in that MAC jurisdiction for enrollment purposes), or have the interpreting physician bill directly for such services.

Unfortunately, for a substantial number of imaging suppliers (such as radiology groups and IDTFs, which are not subject to the anti-markup rule) that rely upon out-of-state teleradiology arrangements, according to our discussions with senior officials at CMS, until the agency publishes guidance to redress this issue, the only way to ensure payment by CMS of claims associated with these out-of-state interpretation services is to have the interpreting physician bill directly for his/her service. The only other option available for imaging suppliers is to accept reassignment from the out-of-state interpreting physician; however, this will require that the imaging supplier must be eligible to enroll in the out-of-state MAC jurisdiction. Notably, the issue remains unclear whether an imaging supplier will be able to enroll in the other jurisdiction if the supplier does not have a practice location in such jurisdiction. CMS has stated that a supplier without a practice location established in the jurisdiction will not be accepted during the enrollment process. During our discussions with CMS, agency officials indicated that they intend to issue further clarification on these issues. Imaging suppliers whose business operations are adversely affected by this recent CMS Change Request should remain alert for a future guidance on this issue by CMS in the form of another Change Request.

Continue reading "CMS's Deletion of "Purchased Interpretations" Causes Problems for Certain Out-of State teleradiology arrangements: Imaging Centers Billing for out-of-State interpretations can Expect Claim Denials " »

March 30, 2010

Impact of the Health Care and Education Affordability Reconciliation Act of 2010 (H.R. 4872)

On March 23, 2010, President Barack Obama signed the Health Care and Education Affordability Reconciliation Act of 2010 (the "Act") into law. As is evident, barring any legal challenges that require a reconfiguration of the law, the Act will have a profound effect upon the business of medicine. By January 1, 2013, a national Medicare pilot program must be established to develop and evaluate paying a bundled payment for acute, inpatient hospital services, physician services, and outpatient hospital services.

The Act includes the following provisions, which are specifically tailored to primary care physicians: (1) the Act supports, through funding and grants, primary care training and capacity-building; (2) the Act establishes grants to provide capitated payments to primary care providers; and (3) the Act requires that Medicaid payment rates to primary care physicians be no less than 100% of the Medicare payment rates in 2013 and 2014 (and provides 100% federal funding for the incremental costs to states in meeting this requirement).

In contrast to certain favorable features, such as the above-referenced provisions relating to primary care physicians, the Act is poised to trigger material adverse consequences for a substantial number of radiology providers. For example, the Act immediately raises the imaging equipment utilization rate assumption (i.e. the time during office hours that imaging equipment is assumed to be in operation) from 50% to 75%. Since this metric is a major factor in determining reimbursement, this is expected to bring about significant reimbursement reductions. According to the American College of Radiology (the "ACR"), these reductions may restrict and possibly eliminate many nonhospital providers' ability to furnish in-office imaging services, especially in rural areas. Further, the ACR takes the position that the imaging reductions will shift necessary imaging care to large hospital providers, thereby increasing the aggregate cost to Medicare for the provision of imaging services, require longer commutes and wait times for patients to receive necessary care, and cause potentially life-threatening delays in diagnosis and treatment of cancer and other serious illnesses.

Continue reading "Impact of the Health Care and Education Affordability Reconciliation Act of 2010 (H.R. 4872)" »

March 30, 2010

Final Interim Rule: Electronic Prescriptions for Controlled Substances

The DEA recently published its Final Interim Rule regarding Electronic Prescriptions for Controlled Substances. This Rule comes almost two years after the DEA published a Notice of Proposed Rulemaking to revise its regulations to allow the creation, signature, transmission, and processing of controlled substance prescriptions electronically (73 FR 36722).

The Final Interim Rule provides practitioners with the option of writing electronic prescriptions for controlled substances and pharmacies with the ability to receive, dispense, and archive these electronic prescriptions. These regulations intend to reduce paperwork for DEA registrants who dispense controlled substances, prescription forgery, and the number of prescription errors caused by illegible handwriting and misunderstood oral prescriptions. Additionally, the DEA hopes that the regulations will help pharmacies and hospitals to integrate prescription records into other medical records more directly, increasing efficiency and reducing the amount of time patients spend waiting to have their prescriptions filled.

Continue reading "Final Interim Rule: Electronic Prescriptions for Controlled Substances" »

March 25, 2010

Florida Medical Center Settles Fraud Suit for $12 Million

A Florida medical center sued for violations of the False Claims Act settled yesterday with the U.S. Justice Department for $12 million. The case was a result of a whistleblower lawsuit filed by the former oncology director of the provider, the Melbourne Internal Medicine Associates P.A. (MIMA). MIMA and its former medical director and practicing radiology oncologist, Dr. Todd Scarborough, were alleged to have defrauded Medicare and TRICARE (the military's health care program) by improperly billed for certain radiation oncology services--including billing for services not rendered, not supervised, duplicate and unnecessary services, and upcoded services.

The Justice Department press release states that their investigation "revealed that the MIMA Cancer Center had defrauded the federal health care programs by improperly inflating claims through various schemes specifically designed to cloak the fraudulent practices."

Both MIMA and Scarborough will pay portions of the settlement.

Continue reading "Florida Medical Center Settles Fraud Suit for $12 Million" »

March 23, 2010

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 because of the program's cost-effectiveness, Section 302 of the Tax Relief and Health Care Act of 2006 made the RAC program permanent required its operation nationwide.

The RAC program soon may be expanding even more. In Section 6411 of H.R. 3590, the "Patient Protection and Affordable Care Act" (i.e., the health care reform bill), Congress has proposed to expand the RAC program, specifically the use of contingency-fee-based RAC contractors, to audit not only Part A and Part B Medicare claims, but also to review Medicare Advantage (Part C), Medicare Prescription Drug (Part D) and Medicaid claims. This bill is in line with a recent White House Memorandum which states President Obama's support of the use of "high-tech bounty hunters" to help find health care fraud in government-run Medicare and Medicaid programs.

The House of Representatives passed H.R. 3590 on March 21, 2010. The bill was approved by the Senate last December and was signed into law today, March 23, 2010. It is unclear which provisions will survive a separate "compromise package of changes" to the bill.

The HLP will continue to provide updates as any changes to the RAC program are adopted and implemented.

Continue reading "Get Ready: The RAC Program Soon May Be Expanding" »

March 19, 2010

Report on Physician Tax Shows Mixed Results

Michigan isn't the first state to consider a tax on healthcare providers to help fund Medicaid. As HLP previously reported, Governor Granholm is pushing again this year for a 3% tax on physician revenue. The taxes can help bring matching federal support for Medicaid, so supporters of the tax argue that physicians who see a significant number of Medicaid patients stand to benefit. A recent study by the Tax Foundation, as reported in the Kaiser Health News, says that results in the 22 states who already have such a tax are showing varied results. In Kansas, for instance, a tax that raises $33 million annually brings in $77 million of federal dollars. On the other hand, in Ohio, the collective burden on hospitals exceeds the rate increases they'll receive from Medicaid by almost $150 million.

March 19, 2010

Purchase of Detroit Medical Center Announced

This morning, the intended purchase by Nashville-based Vanguard Health System of the Detroit Medical Center was announced via a joint press release. Vanguard's Letter of Intent announces that it will invest $850 million into the DMC over the next five years, and promises to keep all eight of DMC's hospitals open for 10 years.

Additionally, Vanguard intends to keep in place DMC's charity care policy and board, though a new regional advisory board will be created to oversee all DMC hospitals. The purchase is contingent on the approval of DMC's central Campus as a Renaissance Zone by Wayne County--which will create significant tax benefits.

The purchase price for Michigan's largest health care system is $417 million.

March 19, 2010

UPDATE: OCR Makes Certain HITECH Enforcement Delay Official

HLP reported earlier this week that the failure of OCR to issue HIPAA regulations regarding the implementation of the HITECH Act was likely to lead to a delay in enforcement of the relevant provisions, though no official delay had been announced.

In an update on its website on Wednesday, OCR has eased some confusion by making the delay official:

Although the effective date (February 17, 2010) for many of these HITECH Act provisions has passed, the [Notice of Proposed Rulemaking] (NPRM) and the final rule that follows will provide specific information regarding the expected date of compliance and enforcement of these new requirements.

The provisions affected include:

  • business associate liability;

  • new limitations on the sale of protected health information, marketing, and fundraising communications; and

  • stronger individual rights to access electronic medical records and restrict the disclosure of certain information.

The update goes on to remind providers that regulations have been issued--and are being enforced--regarding enforcement and breach notification.

Continue reading "UPDATE: OCR Makes Certain HITECH Enforcement Delay Official" »

March 18, 2010

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 Association, Federation of American Hospitals and the National Association of Medical Staff Services, as well as hospital trustees and medical staff attorneys. MS.01.01.01 addresses the medical staff's self-governance and its accountability to the governing body for the quality and safety of patient care, and recognizes that while a hospital's governing body is ultimately responsible for the quality and safety of care, the governing body, medical staff and administration must collaborate to achieve this goal. To facilitate this collaboration, the new standard makes significant changes to the requirements for a hospital's medical staff bylaws and represents a shift of power from the hospital's medical executive committee to the broader voting medical staff. The revised standard becomes effective on March 31, 2011, providing hospitals and their medical staff a full year to understand and incorporate the new requirements and the Joint Commission an opportunity to provide any necessary clarifications.

Continue reading "Joint Commission Approves Revised Medical Staff Bylaws Standard" »

March 17, 2010

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 and readers to be aware of. It shows the direction the OIG is going and where it is focusing its efforts. Some relevant recommendations are below:

1. Due to the high number of hospices that were overdue in their certifications and due to the almost 50% of hospices having health deficiencies, the OIG recommends that CMS adopt statutory or regulatory changes to establish requirements for the frequency of certifications for hospice performance and for enforcing the remedies for a hospice's poor performance.
2. The OIG recommends that CMS strengthens its monitoring practices of hospice claims to ensure that they are properly submitted.

Home Health Agencies:
1. Due to the high levels of medically unnecessary care and fraudulent billing, the OIG recommends that CMS revise its regulations to require physicians to examine Medicare beneficiaries prior to ordering home health services.
2. For those HHAs performing poorly, the OIG recommends that CMS adopt and impose sanctions (besides termination from Medicare) to improve the quality of care.

Laboratory and Imaging Services:
1. To prevent over-utilization of laboratory testing, the OIG recommends that CMS reinstate beneficiary co-insurance and deductibles for lab tests.
2. The OIG recommends that CMS pursue legislation to set accurate and reasonable payment rates for lab tests as the carrier rates for nearly all lab tests varied.
3. Because few counties account for a large percentage of the Part B spending on ultrasound and because 20% of claims raised concern about whether or not they were appropriate, OIG recommends that CMS continue to monitor ultrasound claims to reduce Medicare's vulnerability to questionable ultrasound claims.

Again, these are merely recommendations and have not been implemented. However, they are useful in seeing where the OIG is looking to make changes and what kinds of changes we can expect from CMS in the future. We will continue to keep you apprised of any updates and regulatory changes as they develop.

Continue reading "OIG Releases Compendium of Unimplemented Recommendations" »

March 16, 2010

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 it may delay enforcement of these privacy and security provisions.

OCR intended to issue new HIPAA regulations to meet the HITECH requirements prior to enforcement, and says it still hopes to issue the regs soon enough that a final rule could be issued during 2010. OCR also has not explicitly stated that it will be delaying enforcement--likely to encourage regulated entities to pursue good faith compliance efforts in the meanwhile--though spokesman Mike Robinson has been quoted saying, "It is not correct to characterize an 'effective date' for a legislative provision (which is what the Feb.17, 2010, date is for certain provisions of the HITECH Act) as the 'enforcement date.'"

OCR has also been clear that there will be no delay in enforcing the breach notification rule, which was effective last September.

Continue reading "Office of Civil Rights Hints it May Delay Enforcement of Security Provisions in HITECH Act " »

March 16, 2010

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 Dakota, Connecticut, Mississippi, Indiana, Montana, Texas, and Louisiana. The purpose of the health information exchange is to improve the quality of healthcare delivery by providing incentive payments encourage qualified healthcare providers and hospitals to meaningfully use healthcare information technology.

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March 15, 2010

Update on Reimbursement Freeze

As an update to our March 3 post, the US Senate has passed H.R. 4213 - The American Workers, State, and Business Relief Act -, which if passed by the House of Representatives and signed into law, would extend the freeze to the Sustainable Growth Rate through September 30, 2010. Currently, the physician reimbursement freeze lasts through March 31, 2010. We will continue to keep you apprised of updates as they develop.

Continue reading "Update on Reimbursement Freeze" »

March 11, 2010

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 Medical Equipment, Inc. (Atenas), was convicted on ten counts of healthcare fraud. Between the summer of 2006 and spring of 2007, Aloise submitted nearly $1.5 million in fraudulent claims to Medicare seeking reimbursement for DMEs by using forged prescriptions, certificates of medical necessity, and delivery receipts.

- On February 4, 2010, Yasmanny Benavides of Lacary Medical Services Equipment, Inc. (Lacary Medical) of Miami, Florida was found guilty by a federal jury for committing healthcare fraud and conspiracy to commit healthcare fraud. Lacary Medical provides durable medical equipment (DME) to Medicare beneficiaries. Between July and December of 2003, Lacary Medical submitted almost $5 million worth of false and fraudulent claims seeking reimbursement for DME items and services not prescribed by physicians. Further, Benavides controlled and operated Lily Orthopedic, Inc. (Lily Orthopedic), which also provided DMEs to Medicare beneficiaries in Miami. Between December 2003 and August 2004, Benavides and her co-conspirator Reinaldo Guerro, on behalf of Lily Orthopedic, caused for almost $15 million in false and fraudulent claims to be submitted to Medicare seeking reimbursement for DME items and services not prescribed by physicians.

- On February 8, 2010, Garden State Imaging (GSI) of New Jersey paid over $80,000 for allegedly violating the CMP statute for verbally agreeing to split the proceeds of mobile diagnostic imaging services provided to patients at a medical center between GSI and the owners of the medical center.

- On February 16, 2010, Dr. Harvey Montijo of Florida paid $650,000 for allegedly violating the CMP statute for soliciting and receiving remunerations "in the form of consulting payments from two medical device manufacturers in exchange for using their orthopedic hip and knee products.

This should be a reminder to everyone that the OIG continues to highly enforce and scrutinize healthcare professionals for violations of federal statutes. Please be sure to revisit your compliance programs and polices to ensure that they align with the most recent laws.

Continue reading "OIG Cracks Down First Months of 2010" »

March 10, 2010

President Obama Emphasizes Support of RAC Program

The Medicare Recovery Audit Contractor ("RAC") program has a strong supporter in President Obama. On March 10, 2010, Obama signed a White House Memorandum, which states his support of the use of "high-tech bounty hunters," such as RACs and Medicaid Integrity Contractors ("MICs"), to help root out health care fraud in government-run Medicare and Medicaid programs. The Memorandum directs federal departments and agencies to intensify their use of private auditors to discover and recapture improper payments.

Continue reading "President Obama Emphasizes Support of RAC Program" »

March 8, 2010

ONC Proposes Certification Program for Electronic Health Records Systems

The Office of the National Coordinator for Health Information Technology ("ONC"), an office of the Department of Health and Human Services, released a proposed rule creating a program to certify electronic health records ("EHR") systems. The rule creates both a temporary and a permanent certification system, designed to assure users to that EHR systems and related technology meets the "meaningful use" criteria of the HITECH Act.

This certification is required by CMS for providers to receive payments in an incentive program created by CMS in January for the "meaningful use" of EHR technology.

ONC hopes to issue the final rule regarding temporary certification by the time that HHS issues final rules regarding meaningful use standards and certification criteria. Both are expected this fall.

The permanent certification program, with a longer comment period, will later replace the temporary program.

Continue reading "ONC Proposes Certification Program for Electronic Health Records Systems" »

March 5, 2010

Concerns About Pete Stark Thwart His Assuming the Chairmanship of the House Ways and Means Committee

Rep. Sander Levin, an expert on trade issues, has been tapped to take over the House Ways and Means Committee after Rangel stepped down and Rep. Pete Stark stepped aside. It has been widely reported that concerns by fellow members of the House Ways and Means Committee over Rep. Pete Stark's politics, background and history of controversial statements led to the surprise decision on March 4th to have Congressman Levin replace the embattled Rep. Charles B. Rangel as the committee chairman. Stark had been in line for the powerful post after Rangel announced Wednesday that he was stepping down until a House ethics panel finished investigating him. Based upon the positions that Pete Stark historically has taken to limit revenue-generating opportunities for physicians, the prevailing assumption is that the physician community breathed a collective sigh of relief upon learning of this development.

Continue reading "Concerns About Pete Stark Thwart His Assuming the Chairmanship of the House Ways and Means Committee" »

March 5, 2010

CMS Issues Additional Guidance Regarding Elimination of Consultation Codes

As HLP previously reported, in December, CMS issued MLN Matter 6740 announcing that consultation codes would no longer be used to reflect the different locations where services were provided.

This week, CMS issued additional guidance regarding billing for those services that would previously been coded as consultations. This guidance includes a Questions and Answers on Reporting Physician Consultation Services and Revisions to Consultation Services Payment Policy.

The "Questions and Answers" document includes a wide range of information, including how to bill for services that don't fit classification by a CPT E/M code, how this change affects the definition of transfer of care, how to define new versus existing patients, and whether providers can bill patients for services denied by Medicare for the reason that the incorrect CPT code was billed.

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March 4, 2010

HLP Receives Direct Clarification Regarding HHA Ownership Changes

Recent Medicare regulations regarding ownership changes for HHAs have been the source of controversy and confusion. After numerous attempts by HLP founding partner Robert Iwrey, Esq. to obtain clarification regarding enforcement of these regs, Rob was pleased to receive an email this morning from Frank Whelan, a CMS adminstrator with the Division of Provider and Supplier Enrollment, providing direct clarification. Mr. Whelan's email is below:

If an HHA submitted a CMS-855A ownership change that was received by the Medicare contractor prior to January 1, 2010, the contractor will not apply the 36-month policy found in 42 CFR 424.550(b). As such, if the contractor received a change of ownership or change of information which resulted in a change of owners (e.g., asset sale/stock transfer) prior to January 1, 2010 and the HHA was adversely affected by the contractor's application of the policies found in 424.550(b), the HHA should send a letter to the contractor formally requesting that its ownership change be processed. This letter should include:

*The seller's name, taxpayer identification number, national provider identifier, and the date on which the ownership change was submitted to the contractor.

Contractors will process these pre-January 1, 2010 Medicare enrollment applications under the policies in place prior to January 1, 2010.

While we always encourage providers and suppliers to discuss and resolve enrollment issues with the Medicare contractor, if a HHA encounters a processing problem, we will review it.

Continue reading "HLP Receives Direct Clarification Regarding HHA Ownership Changes" »

March 4, 2010

Pete Stark Replaces Charlie Rangel on House Ways and Means Committee

Yesterday House Speaker Nancy Pelosi selected Congressman Pete Stark of California to head the powerful Ways and Means Committee, replacing New York Congressman Charlie Rangel, who has stepped aside temporarily amid ethics investigations. Stark is best known in health care for first proposing what is now known as "the Stark law," which regulates physician self-referral, in 1988. The first version of the Stark law was passed in 1989.

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March 3, 2010

Congress Extends Freeze in Medicare Reimbursement for 30 Days

Physician reimbursement under the Medicare program will not face a 21% cut, at least not for the next 30 days. Yesterday, on March 2, 2010, the Senate passed the Temporary Extension Act of 2010 (H.R. 4691, 111th Cong. ยง 5 (2010)), which postponed the effective date of a planned 21% fee reduction for an additional 30 days - until March 28, 2010. CMS has stated its belief that Congress will continue to work to avoid implementation of the negative fee schedule update.

The Health Law Partners, P.C. ("The HLP") will continue to keep you apprised as updates occur.

Continue reading "Congress Extends Freeze in Medicare Reimbursement for 30 Days" »

March 2, 2010

HLP Attorney Dresevic Published on Stark and AKS in RBMA Bulletin

One of HLP's founding partners, Adrienne Dresevic, Esq., who specializes in Stark and fraud & abuse analysis, published a new article in the latest issue of the RBMA Bulletin, a publication of the Radiology Business Management Association. Adrienne's article, entitled "Key Regulations Impacting Marketing: Entertainment and Gifts," explains the regulatory limitations placed on health care professionals when marketing, and is a must-read for physicians and other providers trying to expand their business.

Continue reading "HLP Attorney Dresevic Published on Stark and AKS in RBMA Bulletin" »

March 2, 2010

Medicare Reimbursement Reduction Update

On February 22, The Health Law Partners, P.C. ("The HLP") posted a blog urging our clients and friends to help prevent a proposed 21% reduction in Medicare reimbursement. On February 28, the short-term Medicare physician payment freeze expired, triggering the 21% reduction in Medicare reimbursement. Congress is expected to vote within the next several days to extend the payment freeze and stave off the reduction in reimbursement for an additional 30 days - to March 28, 2010.

However, because a vote did not occur prior to the expiration of the physician payment freeze existing in February, triggering the 21% reduction in Medicare reimbursement beginning March 1, if payments were to be made under the cuts, and if the cuts are subsequently repealed, physicians would have to file new claims to recoup lost amounts, creating an administrative burden to both the provider community and Medicare claims processors. According to a recent AP report (3/2, Alonso-Zalvidar), the Obama Administration expects "the Senate will act soon to stave off the cuts," and has "directed Medicare billing contractors to hold off processing claims for 10 business days." Jonathan Blum, director of CMS' Center for Medicare Management, has stated that, CMS' "No. 1 goal is to avoid disrupting payments to physicians during this time."

The HLP will continue to keep you apprised of future developments.

Continue reading "Medicare Reimbursement Reduction Update" »

March 1, 2010

Michigan Office of Health Services Inspector General Created

Following the leads of a number of other States, including New York, Michigan Governor Jennifer Granholm has issued an Executive Order creating an independent Office of Health Services Inspector General (the "OHSIG"). According to the Executive Order, OHSIG, which will be organized as an independent and autonomous entity within the Department of Community Health, is charged with the responsibility to "conduct and supervise activities to prevent, detect, and investigate fraud, waste, and abuse in health services programs" such as Medicaid. The Health Services Inspector General, which will be vested with broad powers to carry out its anti-fraud and abuse mandate, will be appointed by the Governor. The Executive Order becomes effective October 1, 2010.

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