The U.S. Department of Health and Human Services (HHS) recently initiated the Bundled Payments for Care Improvement initiative (Bundled Payments initiative) in an effort to promote better patient health, better care and lower costs. Rather than paying for services separately, the Bundled Payment initiative will bundle payments for services delivered…
Wachler & Associates Health Law Blog
Recent RAC Updates
Additional Documentation Limits for Medicare Providers Effective August 22, 2011, the Recovery Audit Contractors are permitted to request up to 35 records every 45 days from health care providers whose previous record request limit was set at 34 additional documentation requests or less. The limit is based on claim volumes…
New Bill Introduced to Grant Physicians Greater Due Process Rights in Peer Review
A new bill was recently introduced in the House of Representative in an effort to amend the Health Care Quality Improvement Act of 1996 (HCQIA) to require greater due process rights for health care professionals before any reports are made to the National Practitioner’s Data Bank (NPDB). According to the…
OIG Issues Unfavorable Advisory Opinion Regarding an Exclusive Provider Arrangement Between Medical Equipment Supplier and SNF
On July 28, 2011, the U.S. Department of Health and Human Services, Office of Inspector General (OIG) issued an unfavorable advisory opinion regarding two proposals by a supplier of medical supplies, equipment and related services (Supplier) seeking to enter into a contract with a county-operated skilled nursing facility (SNF) to…
Affordable Care Act Requires Medicare Providers to Revalidate Their Enrollment By March 2013
As part of healthcare reform, Section 6401a of the Affordable Care Act requires all providers and suppliers who enrolled in the Medicare program before March 25, 2011 to revalidate their provider enrollment under the new screening criteria. Providers and suppliers who enrolled after March 25, 2011 do not need to…
Recent RAC Updates
DCS Healthcare, RAC for Region A, added two new issues subject to medical necessity reviews to its CMS-approved issues list for providers in Maryland. DCS Healthcare also added four new issues for providers in all Region A states. MS-DRG 286, 287 Cardiac Catheterization for Ischemic Heart Disease (All severity and…
CMS to Release Comparative Billing Reports for Outpatient Physical Therapy Services with the KX Modifer
The Centers for Medicare and Medicaid Services (CMS) recently announced it will release a national provider Comparative Billing Report (CBR) targeting Independent Physical Therapy Providers who practice in the outpatient setting and bill Medicare with the KX Modifier, which is the billing requirement used to show that the beneficiary has…
HHS Estimates $48 Billion of Improper Payments Were Paid to Healthcare Providers in 2010
According to an article by the RAC Monitor, the U.S Department of Health and Human Services (HHS) recently reported that an estimated $48 billion was improperly paid to providers in 2010. However, due to HHS’s currently undeveloped comprehensive projection for the Medicare prescription drug benefit, the U.S. Government Accountability Office (GAO)…
OIG Issues Favorable Advisory Opinion Regarding a Pay-for-Performance Compensation Plan
On July, 25, 2011, the U.S. Department of Health and Human Services, Office of the Inspector General (OIG) issued a favorable advisory opinion regarding an arrangement under which a company (Requestor), who provides administrative services to the State’s Medicaid program, will disburse pay-for-performance payments to physicians and dentists participating in…
MACs Now Responsible for Issuing Medicare Audit Overpayment Demand Letters
On July 29, 2011, the Centers for Medicare and Medicaid Services (CMS) issued Change Request 7436 which shifts the duty of issuing demand letters for identified overpayments from the Recovery Audit Contractors (RACs) to the Medicare Administrative Contractors (MACs). RACs will continue to be responsible for determining whether an improper…