Ashley Morgan

Coverage and Payment of New Products – CPT / HCPCS Code Issues

(January 12, 2016): With the advent of the Affordable Care Act and the changes in the payment incentives that are being developed by payors, including the Medicare and Medicaid programs, many emerging companies are developing new products and devices for the market. While companies will take these products through the regulatory process of obtaining FDA […]

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Providers, Hospitals, and the CJR Program – What You Need To Know!

(January 12, 2016): In our previous article on this subject, we discussed the new Comprehensive Joint Replacement program (CJR program) that CMS has initiated. Under that program, Medicare will pay approximately 800 hospitals in 67 MSAs a bundled payment to cover the costs of virtually all the care that is related to the treatment of

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DME Audits are Back! Are Your Claims Compliant?

(December 22, 2015): The number of durable medical equipment (DME) audits conducted by Zone Program Integrity Contractors (ZPICs) and Program Safeguard Contractors (PSCs) have surged in recent years. Medicare contractors have gradually increased their scrutiny of DME suppliers’ claims. This has resulted in increased postpayment audits of DME suppliers’ claims and associated overpayment demands made

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Looking a Gift Horse in the Mouth (or how to deal with holiday gifts)

(December 8, 2015): Last month we discussed performing audits in your practice. With the winter holidays just around the corner, we are going to take a detour from our process through establishing a compliance program. November, December, January and February bring many holidays and parties. These are usually an opportunity for happiness and cheer, but

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Medicare’s Home Health Probe and Educate Program is Underway

(December 4, 2015): The Centers for Medicare and Medicaid Services (CMS) has directed its contractors to initiate a home health probe and educate program review process with home health agencies around the country. The focus of this program will be to assess agencies’ compliance with the new face-to-face (F2F) documentation requirements that became effective 01/01/15.

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Does Your Practice Have a Compliance Officer or Compliance Committee?

(October 29, 2015): Last month we discussed why having a functioning, effective compliance program is important. If done correctly, a compliance program that is functional, effective, and well-documented is as important as your medical malpractice liability insurance. Indeed, the Affordable Care Act now requires compliance programs and many private payers now explicitly require compliance programs

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CMS Issues New Instructions to its Contractors Regarding the Scope of Claim Appeals

(October 15, 2015): In an effort to stem the ever-increasing tide of claim appeals, CMS recently issued new guidance (MLN Matters SE1521) to its Medicare Administrative Contractors (MACs) and Qualified Independent Contractors (QICs) regarding the conduct of requests for redetermination and reconsideration, respectively. Effective 08/01/15, MACs and QICs may no longer review claims denied during

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Structural Denial of Due Process in HCQIA Peer Review Proceedings

(October 12, 2015): The Federal HCQIA peer review statute affords peer-reviewing bodies and their members legal immunity from liability from suits by the physicians they discipline, so long as their peer-review processes include certain due process rights for the accused physician. These due process rights are expressed as a right to a hearing, and are

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How to Implement a Compliance Plan in Your Practice

(September 17, 2015): Despite the fact that Medicare and Medicaid requires that participating providers implement a compliance plan, most small providers have yet to complete the necessary steps to accomplish this requirement.  “My office manager went to a continuing education program, and she’s come back telling me we need a compliance program. I don’t know about

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