Andrew B. Wachler, Esq. and Jessica C. Forster, Esq. | April 15, 2015

CMS Releases Change Request to Update Sub-Regulatory Guidance for Physician Home Health Certificatio

  On April 10, 2015, the Centers for Medicare & Medicaid Services (CMS) released Change Request 9119 that implements changes to Chapter 7 of the Medicare Benefit Policy Manual pursuant to the CY 2015 Home Health PPS Final Rule published in November 2014.  The changes to the Medicare Benefit Policy Manual will be effective May 11, 2015.  Change Request 9119 introduces changes to the Medicare Benefit Policy Manual, Chapter 7, Section 30.5.1 – Physician …

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Nancy J. Beckley, MB, MBA, CHC | April 15, 2015

Senate Passes SGR: Back to the Future for the Therapy Cap Exceptions Process

Therapy providers no doubt will take comfort in the familiar, as we are once again back to the future with the therapy caps exceptions process that is applicable to all therapy providers billing under Medicare Part B.  The U.S. Senate voted Tuesday evening on HR-2, the “doc fix” bill, to repair the sustainable growth rate (SGR). Tied to the legislation, which had passed in the House prior to Congress recessing for …

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Frank Cohen, MPA | April 15, 2015

Problems with Extrapolation

To begin, I believe that the recent audit of Northwestern reflects the generally poor processes and statistical modeling used by Centers for Medicare & Medicaid Services (CMS) auditors when scrutinizing a healthcare provider. In particular, there seems to be this general idea that there is some degree of homogeneity within the broad range of diagnostic and therapeutic treatments (as well as the delivery of medical supplies, drugs, and other services and …

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04.10.2015
CMS Updates Conditions of Participation for Critical Access Hospitals, Misses Opportunity
CMS Updates Conditions of Participation for Critical Access Hospitals, Misses Opportunity

On April 7, the Centers for Medicare & Medicaid Services (CMS) released an update to the State Operations Manual, Appendix W, which provides the survey protocol, regulations, updates for conditions of participation (CoP), and interpretive guidelines for critical access hospitals (CAHs) and swing beds in CAHs. The 89-page document is wide-reaching, including changes to bed number counting, use of observation...

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04.01.2015
Puzzling Calculations Found in Some Comparative Billing Reports
Puzzling Calculations Found in Some Comparative Billing Reports

Medicare has been sending comparative billing reports (CBRs) for some time. One recent CBR examined the use of modifier -25 by nurse practitioners (incidentally, if you receive an interesting CBR or other communication from Medicare or any other payer, please consider sending me a copy).  There is a LOT to discuss in this report, but before focusing on its specifics, it...

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04.01.2015
Inpatient Order Before Inpatient Only Surgery: Does this Mean We Have Room to Breathe?
Inpatient Order Before Inpatient Only Surgery: Does this Mean We Have Room to Breathe?

Two weeks ago the Centers for Medicare & Medicaid Services (CMS) published an update to the 2015 Hospital Outpatient Prospective Payment System that included two paragraphs that appear to change a longstanding CMS policy that required an inpatient admission order prior to every inpatient-only surgery. CMS seems to be saying that as of April 1, it is allowing the three-day...

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04.01.2015
RAC Revisions and How They will Impact the Provider World
RAC Revisions and How They will Impact the Provider World

With goals to lessen provider burden, increase transparency, and enhance oversight, Recovery Audit Contractors (RACs) are changing. And even bigger changes are around the corner. The most important advice for healthcare providers is to get ready. To help reduce provider burden, the Centers for Medicare & Medicaid Services (CMS) will begin implementing modifications to the RAC program. These include:  Placing limits on...

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CMS

CMS Releases Proposed Voluntary Face-to-…

Andrew B. Wachler, Esq. and Jessica C. Forster, Esq. | 02.18.2015

CMS Releases Proposed Voluntary Face-to-Face Templates for Certifying Physicians

  In January 2015, the Centers for Medicare & Medicaid Services (CMS) released proposed “voluntary” templates for physicians to document face-to-face encounters for home health patients. On Feb. 11, 2015, CMS...

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Feature Articles

Retired ALJ’s Take on the RACs’ Ideas fo…

Gracielinda Prescott | 04.15.2015

Retired ALJ’s Take on the RACs’ Ideas for the Medicare Hearing Process

The Recovery Auditors’ (RACs’) primary lobbyist recently changed its name from the American Coalition for Healthcare Claims Integrity to the Council for Medicare Integrity. Despite using the word “integrity,” both...

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IRF

Wishing You and Your Family Happy Holida…

Angela Phillips, PT - avatar Angela Phillips, PT | 12.22.2014

Wishing You and Your Family Happy Holidays!

To close out the year, we have provided you with a list of resources that provide the framework for inpatient rehabilitation facility (IRF) services. Each of the references has been...

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