CMS has announced its concern regarding the level of compliance for documenting the face-to-face elements necessary for home health care certification.
Attached is an educational piece published by Novitas Solutions on its Part B website.
It lists the qualification criteria for home health benefits:
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It should come as no surprise there are cases in which hospitals seek to and actually do recover income guarantee payments made to physicians whom, either through termination of employment or loss of hospital privileges, fail to fulfill the repayment requirements existing in most of those contractual arrangements.
They typical hospital guarantee arrangement provides advances…
In OIG Advisory Opinion 14-06, the Office of Inspector General (OIG) concluded that payment by a specialty pharmacy to a retail pharmacy on a “per-fill” basis for services provided by the retail pharmacy could violate the Anti Kickback Statute and Civil Money Penalty provisions.
The specialty pharmacy, as the requestor, proposed to pay retail…
It is ironic to learn the Office of Inspector General (OIG) believes the Office of the National Coordinator for Health Information Technology (ONC) essentially has an insufficient compliance program to maintain the privacy and security of the protected health information (PHI) hosted by electronic health records (EHR).
In an August 2014 report (A-06-11-00063), OIG concluded…
Mike Cassidy was published in the July 2014 edition of the Allegheny County Medical Society Legal Bulletin regarding Highmark and UPMC Consent Decree. You can read the article, here.
In the proposed 2015 Medicare Physician Fee Schedule, CMS is seeking comments regarding expanding coverage for secondary interpretation of diagnostic imaging.
I’m enclosing pages 40370 and 40371 of the proposed Medicare Physician Fee Schedule. The enclosed material sites the Medicare Claims Processing Manual provisions which make is clear that a professional component interpretation service should…
In the recently proposed 2015 Physician Fee Schedule, CMS devoted significant resources to discussing potentially misvalued services, which I believe is code for places where CMS would like to reduce reimbursement. One of the areas is global surgery fees.
CMS has concerns with the 10 and 90 day global surgery fees because these global packages…
CMS has issued the Proposed 2015 Physician Fee Schedule and Fact Sheets for specific issues (ASC, ESRD, Home Health, Physician Quality Programs).
SGR Reduction
Although the Protecting Access to Medicare Act Prohibits any SGR reduction for the first 60 days of 2015, i.e., until March 1, 2015, CMS predicts a 20.9% decrease without legislative action.…
Perhaps not coincidentally, immediately following the release of the Questionable Laboratory Payments Special Fraud Alert by the OIG, posted yesterday on the Med Law Blog, the OIG has followed up with Audit Report OIG – 03-11-00730: Questionable Billing for Medicare Part B Clinical Laboratory Services. Below are two quoted paragraphs from the executive…
There has been significantly enhanced scrutiny of financial relationships between referring physicians by both the Office of Inspector General (OIG) and Pennsylvania authorities.
Pennsylvania
Pennsylvania enacted amendments to the Pennsylvania Clinical Laboratory Act on December 18, 2013 (the amendments are referred to as Act 122) and the Department of Health and Bureau of Laboratories just…
