Medicare, Medicaid & Private Payor Updates

Are Medicare ALJs Truly Independent Fact Finders?

(February 20, 2011): Over the years, we have represented a wide variety of health care providers in the administrative appeals process. Our duties have regularly included representation before Administrative Law Judges (ALJs) presiding out of the Western, Southern, Midwestern and Mid-Atlantic Field Offices of the Office of Medicare Hearings and Appeals. (OMHA). In the course […]

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ZPICs Will Deny Claims with “Signature Stamps” and “Date Stamps”

(February 19, 2011): While the use of “signature stamps” has been prohibited for quite some time, a wide variety of health care providers have continued to use “date stamps” or some other method of memorializing when a document was signed by an ordering or treating physician. While the Centers for Medicare and Medicaid Services (CMS)

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ZPIC Participation in ALJ Hearings is Increasing

(February 12, 2011): Over the last year, we have noted an important trend when representing Medicare providers in post-payment overpayment cases at the Administrative Law Judge (ALJ) level of appeal. Medicare contractors are actively attending and participating in many ALJ hearings. In fact, it is now common for a Zone Program Integrity Contractor (ZPIC) to

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2011: The Year of Compliance – Medicare Payment Suspension Actions

(January 26, 2011): Medicare payment suspension action can prove disastrous for your practice or home health agency. How did we get to this point? The recent debate over healthcare in this country has drawn attention to healthcare costs as well as the relationship between healthcare providers and the Federal government. With healthcare costs steadily on

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2011 The Year of Compliance. Avoiding ZPIC Audits and ZPIC Suspension Actions

(January 11, 2011): ZPIC audits and ZPIC suspension actions are a serious risk facing non-hospital providers today. As you recall at the end of 2010 we identified the “Top Ten Health Care Compliance Risks for 2011”. The purpose of this article is to analyze two of those risks; Zone Program Integrity Contractor (ZPIC) audits and

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Top Ten Health Care Compliance Risks for 2011

(December 31, 2010): In case you missed it, Congress, President Obama and the healthcare regulators had a banner year with respect to regulatory activism in 2010. Over the next several weeks we will be releasing a series of articles on our website addressing the compliance risk areas facing your organise dramatic changes and the compliance

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Keeping an Eye on the Medicare AdQIC

(May 16, 2023): The Medicare program is enormous. The Centers for Medicare & Medicaid Services (CMS) estimates that Medicare Administrative Contractors (MAC) process 1.2 billion[1] fee-for-service claims each year in connection with the original[2] (or traditional) Medicare program. If you have ever been involved in a Medicare postpayment audit (or even a prepayment audit[3]) where

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Virginia Judge Concludes That Health Care Reform Law is Unconstitutional

(December 13, 2010):  A Federal Judge for the Eastern District of Virginia concluded that the provision of the recent Health Reform Law may be unconstitutional.  that penalizes/taxes individuals who fail to purchase health insurance, violates the United States Constitution.  In doing so, the Court reaches a different conclusion than two other Federal courts – one

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Provider Exclusion Screening / OIG Screening Practices are a Significant Risk

(December 11, 2010): Has your practice conducted exclusion screening / OIG screening on all of you employees?Earlier this week, HHS-OIG announced that it had assessed significant civil monetary penalties against a health care provider that employed seven individuals who the provider “knew or should have known” had been excluded from participation in Federal health care

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HHS Publishes Proposed Rules on Medicaid RACs

(November 30, 2010): The United States Department of Health and Human Services (“HHS”) recently published a Proposed Rule applying the Recovery Audit Contract (RACs) process to claims under the Medicaid program. As background, the RAC process has been a part of the Medicare program since 2005, first as a demonstration project from 2005 – 2008,

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