E/M Coding Alert - 2016 Issue 7
Physician Notes: CMS: Start Searching Now for Overpayments--Or Face Penalties
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Article Overview
This article covers two separate healthcare compliance topics: CMS guidance on identifying, reporting, and returning overpayments, and HHS OCR guidance on health app developers and HIPAA business associate status. It is relevant to physicians, compliance staff, billing teams, and health IT stakeholders who need to stay current on federal reporting expectations and privacy-related obligations. The article also points readers to official CMS and HHS resources for further information.
Why This Topic Matters
It helps organizations understand federal expectations for overpayment handling and how app-related workflows can create HIPAA business associate considerations, both of which can affect compliance risk.
Article Sections
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Overpayments and CMS reporting timelines
Discusses CMS guidance on identifying overpayments, returning funds, and related compliance exposure. The section emphasizes the broader reporting framework and federal enforcement context.
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Health app developers and HIPAA business associate scenarios
Summarizes an HHS OCR report addressing when mobile health applications may fall within HIPAA-related business associate considerations. The section focuses on general app-use scenarios and privacy compliance context.
What You Will Learn
- How CMS is framing overpayment identification and return requirements
- What general compliance risks are associated with delayed overpayment reporting
- How HHS OCR is describing HIPAA-related considerations for health app developers
- Why app-based workflows can raise privacy and business associate questions
Who Should Read This
- Physicians
- Medical practice administrators
- Compliance officers
- Billing and reimbursement staff
- Health IT and EHR stakeholders
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