This month, the Centers for Medicare and Medicaid Services (“CMS”) published a revised recovery audit contractor (“RAC” or “Auditors”) statement of work (“SOW”) which is, as CMS described, a “contract” between CMS and the Auditors to support CMS in its mission to “reduce Medicare improper payments through the efficient detection and collection of overpayments, the […]
On August 29, 2011, the Department of Health and Human Services Office of Inspector General (“OIG”) issued Advisory Opinion 11-12 in which an operating division of a non-profit corporation (“Requestor”) was seeking an opinion from the OIG regarding its “proposal to enter into arrangements to provide neuro emergency clinical protocols and immediate consultations with stroke […]
The Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) has issued its monthly Recovery Act Oversight report for July 2011. The report revealed what many already know: audits and investigations are have increased considerably since 2009, the year the American Recovery and Reinvestment Act of 2009 (“Recovery Act”) was signed into […]
Wisconsin Physician Services (WPS)–the Part B Medicare Administrative Contractor (MAC) for Iowa, Kansas, Missouri and Nebraska and the Legacy Medicare Carrier for Michigan, Illinois, Wisconsin and Minnesota–regularly conducts Service-Specific Probes (Probes) “to validate potential systematic problems with billing, utilization, and or/documentation of a specific service.” In a recent Probe, 99213–the billing code for established patient […]
Henry Ford Hospital (“Hospital”), a Detroit teaching hospital, applied for Medicare reimbursement for FY 1991-96 and 1998-99 for “pure research” conducted by its residents. In an opinion dated August 18, 2011, the 6th Circuit held that the federal government is not under an obligation to reimburse teaching hospitals for the time their residents conducted pure […]
On September 1, 2011, the Department of Justice, the Department of Health and Human Services (HHS), the FBI and the HHS Office of Inspector General (HHS-OIG) jointly announced that eighteen individuals have been charged in the Eastern District of Michigan for their participation in a series of separate Medicare fraud schemes involving home health and […]
In two reports posted August 30, 2011, the Department of Health and Human Services, Office of Inspector General (OIG) announced that many Independent Diagnostic Testing Facilities (IDTFs) in Miami and Los Angeles failed to comply with selected Medicare standards after unannounced site visits in May and June 2010. An IDTF offers diagnostic services and is […]
Statistics recently released by the Transactional Records Access Clearinghouse (TRAC), a Syracuse University Research organization, show a marked increase in federal health care fraud prosecutions. The statistics show 903 federal prosecutions for health care fraud through the first eight months of 2011, compared to 731 such prosecutions for all of 2010. In addition to the […]
In a press release issued August 23, 2011, the Centers for Medicare & Medicaid Services (CMS) invited health care providers to apply to help test and develop four models of bundling payments. CMS has been working with providers to develop models for bundling payments through the Bundled Payments for Care Improvement Initiative. Medicare currently makes […]
A common reason for claim denials through the Comprehensive Error Testing (“CERT”) program and the medical review process is a lack of provider signatures on orders and medical documentation. Medicare requires that services provided and/or ordered be authenticated by the author. The method of authentication must be a handwritten or electronic signature. Stamped signatures are […]
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