The Department of Health and Human Services Office of Inspector General (“OIG”) issued an Updated Provider Self-Disclosure Protocol (“SDP”) on April 17, 2013 which supersedes the original SDP published in 1998 and three later-released open letters that provided additional guidance. The SDP clarifies that it is only available for “all health care providers, suppliers, or […]
On April 25, 2013, the Centers for Medicare and Medicaid (“CMS”) announced the release of additional information for states on implementation of the Affordable Care Act (“ACA”), part of a series of FAQs addressing the subject. The new FAQ provides information on three topics: 1. The availability of the federal match (75%) for maintenance and […]
On Thursday, April 25, 2013, the Centers for Medicare and Medicaid Services announced that it would delay implementing Phase 2 of its Ordering and Referring Physician Claims Editing program due to technical difficulties. CMS has delayed implementing phase 2 of the program before and it is unclear when it will resolve the technical issues. The […]
On Thursday, April 11, 2013, the Obama Administration released its Budget Request for Fiscal Year 2014 (“FY 2014”) that begins at the beginning of October. If implemented, the Budget Proposal would include approximately $1.8 trillion in savings over the next ten years, enough to replace the automatic sequestration that took effect last month and was […]
Jessica Gustafson, Esq. and Abby Pendleton, Esq., co-chairs of the firm’s Medicare and RAC department authored an ABA Health eSource article titled “CMS Acquiesces to Hospital Pressure, Allows Part B Billing of Hospital Services Following Part A Denial of Inpatient Hospital Claims for Medical Necessity: Is It Enough?” To view this article click here. Continue […]
On March 26, 2013, the Office of Inspector General (“OIG”) of the United States Department of Health and Human Services (“HHS”) issued a Special Fraud Alert (“SFA”) regarding the potential for Physician-Owned Distributorships (“PODs”) to violate the federal Anti-Kickback Statute (“AKS”). While the OIG has provided guidance previously on the potential for physician-owned entities to […]
On March 13, 2013, the Centers for Medicare and Medicaid Services (“CMS”) concurrently issued Ruling CMS-1455-NR (the “Ruling”) and a proposed rule for revising Medicare Part B billing policies in the event of Part A payment denials (the “Proposed Rule”). BACKGROUND Since the conclusion of the Recovery Audit Contractor (“RAC”) demonstration program and prior to […]
On March 8, 2013, the Centers for Medicare and Medicaid Services (“CMS”) issued Transmittal 2668 (Change Request 8180) to Publication 100-04 (Medicare Claims Processing), rescinding and replacing Transmittal 2634 (January 11, 2013). Transmittal 2634 provided clarifications in the manual language to reflect revisions to 42 C.F.R. § 410.69. The newly-released Transmittal 2668 maintained all changes […]
The Department of Health and Human Services (“HHS” or the “Department”) has marginally raised the interest rate on overpayment debts owed to the Department. HHS published notice of the newly certified interest rate for the quarter ended December 31, 2012 in the Federal Register on March 5, 2013. The new rate, 105/8%, represents a ¼% […]
Abby Pendleton, Esq. will be co-speaking with Jack Bert, M.D. and Ranjan Sachdev, M.D. MBA, CHC on March 19, 2013 at the American Academy of Orthopaedic Surgeons Annual Meeting in Chicago. They will be presenting on the topic “Compliance 2013- What You Need to Know”. Continue Reading →
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