CMS offers advice through its Medicare Learning Network Connects bulletin to avoid coding errors. Mistakes happen, and errors do occur in the coding industry. The May 24 Centers for Medicare and Medicaid Services (CMS) Medicare Learning Network (MLN) Connects bulletin included provider compliance information that is noteworthy and important to…
Most compliance decisions involve balancing risk. EDITOR’S NOTE: The following is a summary of a recent broadcast segment on Monitor Monday by the author. Generally speaking, people do a terrible job evaluating risk. Let’s look at a real-world example. There have been some recent accidents involving automated vehicles, including one…
The whole world of opt-out physicians and practitioners creates compliance issues, particularly for coding, billing, and reimbursement Physicians and certain practitioners can elect to opt out of the Medicare program. An affidavit must be filed with a Medicare Administrative Contractor (MAC) first. There is then a two-year process, with the…
Testing for compliance with the CMS-13 list of diagnostic categories can be down through presumptive methodology or medical review.
New policy changes from DOJ will impact False Claims Act cases moving forward. In announcing a significant policy change, the U.S. Department of Justice (DOJ) said that when it concludes that a qui tam case lacks merit, it will file a motion to dismiss the case rather than allowing the…
In another example of Medicare Administrative Contractors (MACs) contradicting the Centers for Medicare & Medicaid Services (CMS), National Government Services (NGS) on Friday issued a news and alert bulletin that was both controversial and confusing. In the alert, NGS stated that outpatient therapeutic pheresis procedures “must be performed by physicians…
Most of us do not think there is anything wrong with being alive. On the contrary, we tend to think there is an awful lot right about it: after all, it is our preferred state of existence. But for those who are kept alive against their expressed wishes to be…
Healthcare regulation is complex. It is often necessary and helpful to involve an expert. While using experts is wise, however, relying on them comes with peril. Expert reports must be carefully scrutinized. A recent experience with two such experts illustrated some of the dangers of placing blind trust in anyone.…
All of the talk in the news about obstruction of justice should serve as a reminder of the importance of knowing what you can and can’t do when a government investigation begins.  Several actions that may sound entirely normal and seem legal can be characterized as obstructing justice. For example,…
With 402 metrics listed in a 55-page guidance sheet, “HCCA-OIG Measuring Compliance Program Effectiveness: A Resource Guide" is a collection of best practices for measuring effectiveness at any U.S. healthcare facility.
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