By Deniza Gertsberg, Esq., on August 27th, 2018 The Centers for Medicare & Medicaid Services (CMS) recently published a proposed rule that, if codified, would bring about sweepings revisions to many Medicare payment policies under the physician fee schedule. Among many other changes CMS is proposing to simplify the documentation requirement for evaluation and management (E/M) code levels 2 through 5 but also proposes a flat fee for those levels of services. These and certain other proposed policy changes are briefly summarized below.
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By Deniza Gertsberg, Esq., on May 31st, 2018 Recent analysis by the Comprehensive Error Rate Testing (CERT) initiative of physical therapy claims revealed that insufficient documentation contributed to improper payments issued to providers.
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By Deniza Gertsberg, Esq., on June 12th, 2017 The Centers for Medicare & Medicaid Services (CMS) has once again issued guidance reminding providers that federal law bars Medicare providers from billing a Qualified Medicare Beneficiaries (QMB) under any circumstances.
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By Deniza Gertsberg, Esq., on December 15th, 2016 Many healthcare providers and suppliers cheered when Congress did away with the sustainable growth rate (SGR) formula by passing the Medicare Access and CHIP Reauthorization Act (MACRA). No longer did they have to worry on an annual basis if a patch to prevent double digit cuts to reimbursement will be passed. But a new reimbursement methodology under MACRA leaves many practitioners wondering if they will meet the metrics or face payment cuts.
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By Deniza Gertsberg, Esq., on August 24th, 2016 In a recent federal register publication the Centers for Medicare & Medicaid Services (CMS) announced the extension of temporary moratoria already in place on the enrollment of new Medicare Part B nonemergency ground ambulance suppliers and Medicare home health agencies (HHAs), subunits, and branch locations in specific locations within designated metropolitan areas in Florida, Illinois, Michigan, Texas, Pennsylvania, and New Jersey. Additionally, a statewide ban covering additional programs, Medicaid and Children’s Health Insurance Program (CHIP, was also announced.
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By Deniza Gertsberg, Esq., on July 11th, 2016 Healthcare practitioners should be aware of important updates and changes to Medicare and Medicaid Programs of New York and New Jersey. We summarize some of these changes in the article that follows.
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By Deniza Gertsberg, Esq., on May 31st, 2016 The passage of the Protecting Access to Medicare Act (Act) of 2014 ushered in a new era for Medicare laboratory reimbursement rates not seen in three decades.
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By Deniza Gertsberg, Esq., on March 24th, 2016 The Centers for Medicare & Medicaid Services (CMS) has issued number of recent updates to the Medicare program which impact various providers and suppliers.
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By Deniza Gertsberg, Esq., on March 4th, 2016 The Centers for Medicare & Medicaid Services (CMS) has once again proposed new rules which would enhance the screening requirements for providers and suppliers. The rule proposals would ratchet up the scrutiny on provider enrollments and toughen suspension and revocation penalties.
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By Deniza Gertsberg, Esq., on February 24th, 2016 Every year the Office of the Inspector General (OIG) issues a workplan that identifies the agency’s planned audit activities for the upcoming year. The workplan offers valuable information for healthcare entities by providing them with an opportunity to conduct appropriate risk assessments, and, where indicated, to modify the entity’s compliance program.
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By Deniza Gertsberg, Esq., on February 11th, 2016 Recent results from the Comprehensive Error Rate Testing (CERT) Program revealed that the majority of improper payment for laboratory service result from insufficient documentation. This article summarizes important documentation recommendations from CMS.
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By Deniza Gertsberg, Esq., on January 29th, 2016 Each year certain providers attempt to enroll in the Medicare program to participate and bill for services. The Centers for Medicare & Medicaid Services (CMS), however, instructs the Medicare contractors that review and process enrollment applications, to deny applications from providers ineligible to participate with Medicare.
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By Deniza Gertsberg, Esq., on January 13th, 2016 Consistently over the years the Office of Inspector General (OIG) has targeted chiropractic services for audits. In fact, chiropractic services appear annually on the OIG’s workplan agenda. In September 2015, the OIG issued a report recommending that the Centers for Medicare & Medicaid Services’ (CMS) establish better controls and measures to prevent questionable payments, collect overpayments based on inappropriately paid claims and ensure that claims are paid only for Medicare-covered diagnoses.
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By Deniza Gertsberg, Esq., on September 14th, 2015 The Centers for Medicare & Medicaid Services (CMS) recently announced another six month extension of moratoria on new home health agencies, home health agency sub-units, and Part B ground ambulance suppliers in certain locations throughout the country.
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By Deniza Gertsberg, Esq., on July 8th, 2015 In a welcomed move, the Centers for Medicare & Medicaid Services (CMS) and American Medical Association (AMA) announced elimination of certain sanctions and penalties during ICD-10 transition and the availability of additional resources to help physicians get ready for ICD-10.
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By Deniza Gertsberg, Esq., on February 11th, 2015 Last year, CMS issued a final rule which requires prescribers of Part D drugs to be either enrolled with Medicare or have submitted an opt-out affidavit to their Medicare Administrative Contractor (MAC) in order for a prescription to be eligible for coverage under the Part D program. See 42 CFR § 423.120(c)(5) and (6).
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By Deniza Gertsberg, Esq., on September 4th, 2014 On August 6, 2014, the Centers for Medicare and Medicaid Services (CMS) began implementing a new fingerprint-based background check requirement for individuals with 5% or greater ownership interest in providers and suppliers that fall into a high-risk category and are either currently enrolled or have pending enrollment in Medicare. This screening process will be conducted in phases and not all entities in the high-risk screening category will be subject to the first phase.
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By Deniza Gertsberg, Esq., on September 2nd, 2014 On July 29, 2014, the Centers for Medicare and Medicaid Services (CMS) announced an extension on the temporary moratoria on new provider enrollment applications as well as on applications adding additional practice locations for Home Health Agencies (and related sub-units) and Part B ambulance suppliers. The temporary moratoria is for an additional six months.
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By Deniza Gertsberg, Esq., on July 29th, 2014 On July 30, 2011, the Centers for Medicare & Medicaid (CMS) implemented its new Fraud Prevention System (FPS), which uses predictive analytics technology, similar to that utilized by credit card companies, to move away from the “pay and chase” model to instead detect aberrant or fraudulent billing patterns prior to payment of claims. According to CMS, by fiscal year 2013, CMS was able to take administrative action against 938 providers and suppliers using FPS, saving or preventing $210.7 million in payments.
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The Centers for Medicare & Medicaid Services (CMS) announced that it will begin implementing the fingerprint-based background checks for providers and suppliers in certain risk categories.
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