Ronald Hirsch, MD, FACP, CHCQM | November 30, 2016

Observation Infographic: Misleading and Dangerous

On a Monitor Mondays broadcast in July, I reported that The Center for Medicare Advocacy had received half a million dollars from the John A. Hartford Foundation to “raise awareness” of the negative consequences of what they call “observation status” (observation is service provided to patients whose status is listed as outpatient, but I will refer to it simply as “status” in this article). Details about the first result of that …

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Gracielinda Prescott | November 30, 2016

2017 OIG Work Plan: Compliance Lessons

The good thing about compliance is that there is always a roadmap to rely upon and guidance from the enforcement authorities on where to focus your compliance efforts. The “go-to” document issued each year is the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) Work Plan. The OIG released its 2017 Work Plan in November, and there is a lot that can be learned by reviewing …

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Shannon Deconda, CPC, CPC-I, CEMC, CMSCS, CPMA® | November 30, 2016

What Do You Expect From an Independent Audit? Part II

EDITOR’S NOTE: Here is the second installment by the author. Part I appeared in the Nov. 17, 2016 edition of the RACmonitor eNews. Earlier we discussed the approach and reasoning for audits, and how that should drive the findings to separate “this will do” from “this is compliant documentation.” It’s hard to know if a third-party auditing firm is going to provide this type of review for you. I was working …

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11.21.2016
The Big “opps” in the OPPS
The Big “opps” in the OPPS

Perhaps the biggest news out of the 2017 Outpatient Prospective Payment System (OPPS) final rule is something that didn’t happen. The proposed rule was going to prevent off-campus, provider-based entities from offering any new services that were not within a clinical family furnished and billed as of Nov. 2, 2015.  the Centers for Medicare & Medicaid Services (CMS) opted not...

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11.21.2016
Provider-Based Rule: Surprises and Disappointments
Provider-Based Rule: Surprises and Disappointments

There are two sections of the Federal Register entry of the 2017 Outpatient Prospective Payment System final rule that address the implementation of Section 603 of the Bipartisan Budget Act (BiBA) of 2015. This involves congressionally mandated payment changes for off-campus, provider-based clinics and operations. Interestingly enough, the provider-based rule (PBR) found at 42 CFR §413.65 is not materially changed. The...

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11.21.2016
IRF Quality Measures: Still Some Confusion About the Assessment Period
IRF Quality Measures: Still Some Confusion About the Assessment Period

The Centers for Medicare & Medicaid Services (CMS) last month posted responses to questions submitted at the time of the August federal inpatient rehabilitation facility (IRF) training for quality measures. The entire document can be found on the IRF quality reporting training website here: (Q&A).  Based on the questions and responses in that document, one thing is clear:  the who, how,...

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11.22.2016
Verbal Order Authentication Prior to Discharge Not Always Required
Verbal Order Authentication Prior to Discharge Not Always Required

I recently received an email from a case manager who was questioning something I had said at a conference about condition code 44. She wrote, “We continue to have problems with our billing department that insists on ‘stop billing’ accounts where a compliant Condition Code 44 process was done but the order for observation was not signed until after the...

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OIG

News Alert: OIG, DOJ Moves Serve as Ster…

Bret Bissey, MBA, FACHE, CHC | 10.03.2016

News Alert: OIG, DOJ Moves Serve as Stern Warning for Providers

Those involved in healthcare compliance should be aware of two recent and significant developments coming from the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG)...

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Feature Articles

How CERTain Are We About the CERT Result…

Frank D. Cohen, MPA, MBB | 11.30.2016

How CERTain Are We About the CERT Results?

I recently was reading through the Nov. 15 Centers for Medicare & Medicaid Services (CMS) blog post written by Shantanu Agrawal, M.D., Deputy Administrator and Director for Center for Program...

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IRF

Nordian Posts Results of Recent Oregon P…

Angela Phillips, PT - avatar Angela Phillips, PT | 05.04.2016

Nordian Posts Results of Recent Oregon Probe Audit:  Once Again, No Surprises for IRFs in the Results

Last month, we discussed Noridian’s findings from the IRF Probe Audit for Arizona conducted from December 21, 2015, through March 3, 2016. At that time, we agreed to provide the...

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