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Wachler & Associates Health Law Blog

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CMS Announces Delay of Power Mobility Device Demonstration Program

On December 29, the Centers for Medicare and Medicaid Services (CMS) announced that it would delay the start of the Prepayment Review and Prior Authorization of Power Mobility Devices (PMDs) Demonstration Program. CMS originally announced the demonstration program on November 15 and followed the announcement with special Open Door Forums…

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CMS Implements 3-day Payment Window Policy for Wholly Owned or Wholly Operated Physician Practices

Recently, the Centers for Medicare and Medicaid Services (CMS) released Change Request 7502 relating to the 3-day payment window policy. For services on or after January 1, 2012, the 3-day payment window will apply when a patient is seen in a physician practice that is wholly owned or wholly operated…

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Ten Highlights from the Proposed Physician Payment Sunshine Act Rule

In the December 19, 2011 Federal Register, CMS published a Proposed Rule to implement the “Physician Payment Sunshine Act” portion of Patient Protection and Affordable Care Act (PPACA), or health care reform, which requires drug, medical device, biological and medical supply manufacturers to track and report payments made to physicians…

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CMS’ Special Open Door Forum on Recovery Auditor Pre-Payment Review Demonstration Program

On December 21, the Centers for Medicare & Medicaid Services (“CMS”) held a special Open Door Forum (“ODF”) for the Recovery Auditor Pre-Payment Review Demonstration Program announced on November 15 along with two other demonstration programs, all of which will become effective on January 1, 2012. The ODF, in which…

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CMS to Reopen Home Health Claims Denied Based on Face-to-Face Requirements

CMS has announced that it is requiring Medicare to reopen claims that contractors denied because Home Health Agencies (“HHA”) allegedly did not comply with “Face-to-Face” encounter requirements put in place by the Patient Protection and Affordable Care Act (“ACA”), or Health Reform legislation. The Face-to-Face encounter rules require that the…

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CMS Announces Special Open Door Forum for the Recovery Auditor Pre-Payment Review Demonstration Program

On Wednesday, December 21, the Centers for Medicare and Medicaid Services (CMS) will hold a Special Open Door Forum on the Recovery Auditor Pre-Payment Review Demonstration Program. The Demonstration Program is a mandatory program for providers in 11 states, including: CA, FL, IL, LA, MI, MO, NC, NY, OH, PA…

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CMS AB Demonstration Program: Hospitals’ Participation in December 8 Open Door Forum

As discussed in earlier posts, hospitals that participate in CMS’ upcoming Part A to Part B Rebilling Demonstration Program will be required to waive their right to appeal claims denied for lack of medical necessity for services provided in the inpatient setting. CMS’ rationale for this “all or nothing” approach…

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Open Door Forum for Part A to Part B Rebilling Demonstration Program

This afternoon, CMS conducted the first special Open Door Forum (ODF) on the Part A to Part B Rebilling Demonstration Program. The ODF involved a brief overview of the Demonstration Program followed by many questions by the ODF participants. Although the ODF provided some clarification on the Demonstration Program, CMS’…

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CMS Releases Last Quarter’s Data on Medicare RAC Collections

The Centers for Medicare and Medicaid Services (CMS) has recently released the Medicare RAC collections data for the last quarter of 2011 fiscal year. Recovery auditors identified $277.1 million in overpayments and $76.6 million in underpayments, for a total claims’ correction of $353.7 million, which was 22 percent higher than…

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CMS Releases Part A to B Rebilling Demonstration Program Enrollment Application

This week CMS released more information regarding the Part A to Part B Rebilling Demonstration Program. Now available on CMS’ website is the enrollment application for hospitals to complete to seek to participate in the program. The enrollment application includes language which reiterates that participation in the Demonstration Program is…

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