February 27, 2020
By Frank D. Cohen, MPA, MBB The New World of Auditing
What’s next for auditing professionals? The first thing to note here is that I am not an auditor. So, for me to write an article on auditing tips might seem a bit unusual. But this is not an article on auditing compliance, but rather on being an auditor – and…
February 20, 2020
By Frank D. Cohen, MPA, MBB Why Auditors Can’t be Unbiased
A short lesson on game theory. Last week on Monitor Mondays, Knicole Emanuel, Esq. reported on the case of Commonwealth v. Pediatric Specialist, PLLC, wherein the Recovery Audit Contractors’ (RACs’) experts were prohibited from testifying because they were paid on contingency. This means that the auditor (or the company for…
December 19, 2019
By Knicole C. Emanuel Esq. Positive Airway Pressure Device Supplies on the Medicare Audit Chopping Block…Again
EDITOR’S NOTE: While presenting at the recent New England Healthcare Internal Auditors (NEHIA) annual conference in Connecticut, Knicole Emanuel encountered the recurring audit topic of positive airway device supplies or PAPs. The following is her report. Back in 2014 and 2015, then again in 2018, PAPs were the main area…
December 12, 2019
By Sean M. Weiss, CEMA, CMCO, CPMA, CPC-P, CMPE, CMPM, CPC-P Early Warning: Top Audit Risks for 2020
Three risks, in particular, are expected to pose a greater liability for providers. As we get ready to say goodbye to another year of audits and investigations, compliance officers around the country have worked or are working to determine their audit elements for calendar year 2020, in response to the…
By Knicole C. Emanuel Esq.
Oct. 1, 2019 marks the beginning of a new era of billing for skilled nursing facilities (SNFs). Say goodbye to RUG-IV, and hello to the Patient-Driven Payment Model (PDPM). This is a daunting task, not for the faint of heart. Under PDPM, reimbursement for Medicare Part A patients in SNFs…
By Frank D. Cohen, MPA, MBB
There are now 200,000 new targets for CMS and private payers. Since the first of this year, I have engaged in several audits for which the target is not the physician, but rather a physician’s assistant (PA) or a nurse practitioner (NP). While there have always been audit issues regarding…
November 16, 2017
By Ronald Hirsch, MD Medical Necessity, IRF and DME: Three New Potential RAC Targets
CMS has posted three new issues the RACs have proposed for auditing, pending CMS evaluation and approval. Last week the Centers for Medicare & Medicaid Services (CMS) created a new page on its Recovery Audit Contractor (RAC) website titled Provider Resources. CMS indicated that it will post on this page…
August 31, 2017
By David M. Glaser, Esq. Training Should Not Exaggerate Regulatory Framework
Recent articles have described the regulatory complexity surrounding signatures and credentials in the world of healthcare. There’s a practical question associated with this: How do you train people to comply with a best practice without mischaracterizing the state of a law? This question is really important. Perhaps my favorite activity as a lawyer…
By Juliet B. Ugarte Hopkins, MD, CHCQM-PHYADV
The topic of Condition Code 44 is not new. Detailed by the Centers for Medicare & Medicaid Services (CMS) in September 2004 via MLN Matters SE 0622, titled Clarification of Medicare Payment Policy When Inpatient Admission is Determined not to be Medically Necessary, Including the Use of Condition Code 44:…
July 19, 2017
By Michael A. Salvatore, MD, FACP Carving Up the Hospice Pie: Out, In, and In and Out
According to Patti Smith, the American laureate of punk rock, “You can't carve up the world. It's not a pie.” Perhaps you cannot carve up the world but Medicare has proposed carving up—or more accurately, carving in—the hospice pie to Medicare Advantage (MA) programs. To appreciate the potential import of…
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- Allen Jost, PhDAlvin Gore, MD, CHCQM and Cathi Charlberg, LVN, CHCQMAmanda Gilliland, RN, BSNAmber Soucy, MSN, RNAndrew B. Wachler, Esq.Andrew B. Wachler, Esq. and Emma E. TrivaxAndrew H. Hughes, MD and Charles Locke, MD, CHCQM-PHYADVAndrew Wachler and Kaitlin NucciAndrew Wachler, Esq., and Sarah Hillegonds, Esq.Angela Phillips, PTAspen AlbrightBarbara Vandegrift, RN, BSN, MABecky Rodrian, CPC, CEMC, CBCS, MBSBenjamin Kartchner MD, CHCQM-PhyAdvBrian T. LandryChristina Panos, RHIA, CTRChristopher Halleman, DOChristopher J. Laney, Esq.Chuck BuckClark AnthonyColleen Morley, DNP, RN, CCM, CMAC, CMCN, ACM-RNDaniel Zirkman, MDDavid A. McKenzie, CAEDavid Jury MD, MSDavid M. Glaser, Esq.Delilah Davis, RN, BSN, CCADenise Coleman, LPNDenise Nash, MD, CCS, CIMDheeraj Mahajan, MD, FACPDuane Abbey, PhD, CFPEdward Roche, PhD, JDElizabeth C. Dunbar, MD, MBA, FACEP, CHCQM-PHYADVEllen Fink-Samnick MSW, ACSW, LCSW, CCM, CRPEllen Parucka Walker LCSW ACSWErica E. Remer, MD, FACEP, CCDSErin Diesel Roumayah, Esq.Frank D. Cohen, MPA, MBBGlenn Krauss, RHIA, BBA, CCS, CCS-P, CPUR, CCDS, C-CDI, PCS, FCS, C-CDAMGloryanne Bryant, RHIA, RHIT, CCS, CCDSGreg FordHolly Louie, RN, BSN, CHBMEJ. Paul Spencer, CPC, COCJanelle Ali-Dinar, PhDJeffrey D. Lehrman DPM, FASPS, MAPWCAJessica Forster, Esq.John K. Hall, MD, JD, MBA, FCLM, FRCPCJulia K. Brodt, PhDJuliet B. Ugarte Hopkins, MD, CHCQM-PHYADVKaitlin Nucci Esq.Kathleen K. Borchard, BSN, RN-ACMKathy Seward, MD, CHCQM-PHYADVKim T. Charland, BA, RHIT, CCSKnicole C. Emanuel Esq.Kristi Pollard, RHIT, CCS, CPC, CIRCC, AHIMA-approved ICD-10-CM/PCS trainerLaurie M. Johnson, MS, RHIA, FAHIMA AHIMA Approved ICD-10-CM/PCS TrainerLeslie Marsh, RN, BS, MSN, MBALori O’Hara, MA, CCC-SLPMadison AllenMaggie Elehwany, JDMark SpiveyMarvin D Mitchell, RN, BSN, MBAMary Beth Pace, RN, BSN, MBA, ACM, CMACMary Inman, Esq. and Anne Hayes Hartman, Esq.Mary Inman, Esq. and Max Voldman, Esq.Matt Lambert, MDMatthew AlbrightMaureen Testoni Esq,Max Voldman, Esq.Melinda Battaile, MD, FHM, MMCI, CHCQM-PHYADV, CCDSMichael A. Salvatore, MD, FACPMichael KennedyMichael Rosen, Esq.Nancy J. Beckley, MB, MBA, CHCNena Scott, MSEd, RHIA, CCS, CCS-P, CCDSPhillip Angello, MDRalph Wuebker, MD, MBARichard “Dick” Beckley, YNS, USN, 1966-1970Ronald Hirsch, MDSarah Hillegonds, Esq.Sean M. Weiss, CEMA, CMCO, CPMA, CPC-P, CMPE, CMPM, CPC-PSean Weiss, CHC, CEMA, CMCO, CPMA, CPC-P, CMPE, CPC and David Glaser, Esq.Shannon Deconda, CPC, CPC-I, CEMC, CMSCS, CPMA®Stanley Nachimson, MSStefani Daniels, MSN, RN, CMAC, ACM and Tiffany Ferguson, LMSW, ACM
