On June 9, 2015, the Office of Inspector General (OIG) issued a Fraud Alert titled “Physician Compensation Arrangements May Result in Significant Liability,” which is available here. In the Fraud Alert, the OIG warns physicians of the dangers of entering into compensation arrangements with health care entities, such as medical directorships or office staff arrangements, […]
On June 9, 2015, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a fraud alert warning physicians of significant liability for entering into medical directorships that are non-compliant with the federal Anti-Kickback Statute (AKS). Medical directorships must reflect fair market value for bona fide services that the physicians actually […]
As expected, the U.S. Department of Health and Human Services (“HHS“) officially set the ICD-10 compliance date for October 1, 2015. Previously, providers and payors had until October 1, 2014 to transition from the ICD-9 to the ICD-10 Procedure Coding System. However, the Protecting Access to Medicare Act of 2014 prevents HHS from adopting ICD-10 […]
In the recently released Federal Register, The Office of Inspector General (OIG) informed the public that that it intends to update the Provider Self-Disclosure Protocol (the Protocol) and is soliciting input. The Protocol, which was first introduced in 1998, is the process that health care providers can take in order to disclose potential fraud involving […]
The House and Senate passed a revised version of H.R. 3630, the Middle Class Tax Relief and Job Creation Act of 2012, which guarantees that physicians will avoid a 27.4 percent cut in Medicare reimbursement for an additional ten months. Instead of the schedule cuts which were expected to be enacted on March 1, physician […]
On February 7, 2012, The Centers for Medicare and Medicaid Services (CMS) released a Request for Comments regarding two demonstration programs it intends to conduct. The first, the Recovery Audit Prepayment Review Demonstration, will allow CMS and its agents to request additional documentation, including medical records, to support submitted claims. In Chapter 3 of the […]
WPS, the Legacy Part B Medicare Administrative Contractor for Illinois, Michigan, Wisconsin and Minnesota, has issued recent guidance regarding documentation of discard or waste for drugs and biologicals as well as missing information on the Medicare CMS-855 provider enrollment applications. Notably, WPS voices CMS’ direction that physicians, hospitals, and other providers “make good faith efforts […]
With the onslaught of the new Patient Protection and Affordable Care Act (PPACA) provisions making it a false claim to retain known overpayments and the new CMS guidance on the newly-reinstated Voluntary Self-Referral Disclosure Protocol (SRDP), Wisconsin Physician Services (WPS)–the Medicare Part B Contractor for Illinois, Michigan, Wisconsin, and Minnesota–released its revised overpayment notification and […]
On September 30, 2010, the Arkansas Supreme Court held that Baptist Health, a private, charitable, nonprofit corporation, may not impose an Economic Conflict of Interest Policy (Policy). In this case, “the Policy mandates the denial of initial and renewed professional staff appointments or clinical privileges at any Baptist hospital to any practitioner who, directly or […]
Health and Human Services (HHS) announced that it launched its new HealthCare.gov Facebook page. According to HHS Secretary, Kathleen Sebelius, “HealthCare.gov on Facebook offers Facebook users a new tool to understand and stay informed about the Affordable Care Act…This new page is another resource that people can use to learn about and discuss health care […]
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