tci Medicare Compliance & Reimbursement - 2003 Issue 17

PROGRAM MEMO ROUNDUP

Hospitals that "self attest" their provider-based entities could save themselves a bundle if the Centers for Medicare & Medicaid Services later denies their provider-based status. So says CMS in an April 18 program memorandum (A-03-030; http://cms.hhs.gov/manuals/pm_trans/A03030.pdf) that offers an overview of provider-based status rules. The agency says that if it denies provider-based status, it would collect overpayments going back to the submission of the attestation for self-attesting facilities, but would pursue overpayment all the way back to Oct. 1, 2002 for non-self-attesting organizations. In other recent program memoranda, CMS: urges durable medical equipment regional carriers to...

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