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Are You Aware of Medicare Advantage Plans Timely Filing Rules?
August 20th, 2019
By Aimee Wilcox | Published August 20th, 2019
The Medicare Fee for Service (FFS) program (Traditional or Original Medicare) has a timely filing requirement; a clean claim for services rendered must be received within one year of the date of service or risk payment denial.
As any company who has billed Medicare services can attest, the one-year timely filing ...
Will Medicare Change Their Rules Regarding Coverage of Services Provided by a Chiropractor?
August 13th, 2019
By Wyn Staheli, Director of Research | Published August 13th, 2019
Two separate pieces of legislation introduced in the House of Representatives (H.R. 2883 and H.R. 3654) have the potential to change some of Medicare’s policies regarding doctors of chiropractic. Find out what these two bills are all about and how they could affect Medicare policies.
The OIG Work Plan: What Is It and Why Should I Care?
August 9th, 2019
By Namas | Published August 9th, 2019 - Last Review/Update August 14th, 2019
The Department of Health and Human Services (HHS) founded its Office of Inspector General (OIG) in 1976 and tasked it with the responsibility to combat waste, fraud, and abuse within Medicare, Medicaid, and the other HHS programs. With approximately 1,600 employees, HHS OIG is the largest inspector general's office within ...
By Wyn Staheli, Director of Research | Published July 22nd, 2019
There are many things that can be missed when trying to run an effective and profitable practice. This article covers some important tasks that are often overlooked such as not reviewing your payer contracts or failing to check eligibility.
Q/A: Can I Put the DC’s NPI in Item Number 24J for Massage Services?
July 8th, 2019
By Wyn Staheli, Director of Research | Published July 8th, 2019
Question:
Are there scenarios in which it is acceptable to put the DC's NPI in box 24j for massage services?
Answer:
While the answer to this is yes, it is essential to understand that there are very limited scenarios. In most cases, Item Number 24J is only for the NPI of the individual ...
Rules for Rendering Unproven, Investigational or Experimental Procedures
July 1st, 2019
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published July 1st, 2019
If you haven’t reviewed your state guidelines or taken a recent look at third-party payer policies on unproven, investigational or experimental procedures, now is the perfect time to make sure you’re up to speed with this important information. Most providers are surprised to see commonly used devices or techniques listed ...
By Wyn Staheli, Director of Research | Published July 1st, 2019
Question:
I heard that I need to have an interpreter if someone who only speaks Spanish comes into my office. Is this really true?
Answer:
Yes! There are both state and federal laws that need to be considered. The applicable federal laws are:
Title VI of the Civil Rights Act of 1964,
Americans with Disabilities ...
2018 Medicare Improper Payment Report Shows Slight Improvement but There's Still Work to be Done
June 27th, 2019
By Wyn Staheli, Director of Research | Published June 27th, 2019 - Last Review/Update July 8th, 2019
The Medicare Improper Payment Report for 2018 is not a measurement of fraud. Rather, it is an estimate of the claims paid by Medicare which did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from July 1, 2016 through June 30, 2017, was 91.9 percent. ...
Q/A: Can I Refuse to File a Patient's Medical Insurance for an Auto Accident?
June 25th, 2019
By Wyn Staheli, Director of Research | Published June 25th, 2019
Question:
Can a Chiropractor refuse to file a patients Medical Insurance for an Auto Accident?
Answer:
There isn't a simple answer to this question. It depends on who is responsible and state laws. Who is responsible (the auto insurance or the medical insurance) can depend on state requirements as well as who is ...
By Namas | Published June 21st, 2019 - Last Review/Update June 27th, 2019
Small Breaches Can Be Subject to Large Penalties
We may have heard about the large fines issued by the Office for Civil Rights (OCR) against big organizations like Anthem or the University of Texas MD Anderson Cancer Center. These organizations have been in the news due to privacy breaches that constituted violations ...
What Medical Necessity Tools Does Find-A-Code Offer?
June 13th, 2019
By Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content | Published June 13th, 2019
Find-A-Code is a great resource for individuals working in all aspects of healthcare, from providers and ancillary staff to the attorneys and payers who assess and critique the documentation supporting the services performed. When recently asked what tools Find-A-Code has to help support medical necessity, our response was, "We provide many resources ...
Q/A: Two Payers Both Paid the Claim. Who Gets the Refund?
May 13th, 2019
By Wyn Staheli, Director of Research | Published May 13th, 2019
Question
We have a personal injury situation where we submitted a claim was sent to the patient's auto policy carrier who refused payment. We then submitted it to her other insurance. Eventually, both companies paid her claims. Her auto paid at full value, and her secondary paid at a reduced rate ...
Q/A: I’m Being Audited? Is There a Documentation Template I can use?
April 29th, 2019
By Wyn Staheli, Director of Research | Published April 29th, 2019
Question: Our Medicare contractor is auditing claims with 98942. Do you have any suggestions for a template for documentation to warrant the use of 98942?
Answer: When you submit a claim with code 98942 you are stating that you have determined that it was medically necessary to adjust all 5 of ...
OIG Announces New Review For Medicare Part B Payments for Podiatry and Ancillary Services
April 23rd, 2019
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published April 23rd, 2019
Due to prior OIG work identifying inappropriate payments for podiatrists and ancillary services, the OIG announced in Feb 2019 they will begin a new review starting in 2020. The OIG stated they will review Medicare Part B payments to determine if medical necessity is supported in accordance with Medicare requirements.
Part of the ...
By Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content | Published April 23rd, 2019
Have you ever assigned a high-complexity E/M code (e.g., 99205, 99215, 99223, 99233, 99245, etc.) and wondered if it would stand up to further scrutiny? Well, let’s take a closer look at the requirements for reporting high-level E/M services.
Both the American Medical Association and Medicare-published E/M Guidelines agree that a ...
By Wyn Staheli, Director of Research | Published April 15th, 2019
In Chapter 3 — Compliance of the ChiroCode DeskBook, we warn about the dangers of disgruntled people (pages 172-173). Even if we think that we are a wonderful healthcare provider and office, there are those individuals who can and will create problems. As frustrating as it may be, there are ...
By Wyn Staheli, Director of Research | Published April 8th, 2019
Any type of payer review can create some headaches for providers and cause problems for a healthcare office. Even for a practice that has taken administrative steps to try and prevent a prepayment review, it can still happen. A prepayment review means that you must include documentation WITH your claim. ...
Clearing Up Some Medicare Participation Misunderstandings
March 25th, 2019
By Wyn Staheli, Director of Research | Published March 25th, 2019 - Last Review/Update April 2nd, 2019
Even though we may think we truly understand what it means to be a participating provider, Medicare doesn’t quite work the way that other insurance plans do. Far too many providers do not understand the difference and get into hot water. To further complicate matters, the rules are different for ...
Q/A: How do we Know Which Codes a Payer Will Allow?
March 22nd, 2019
By Wyn Staheli, Director of Research | Published March 22nd, 2019
How do we know which codes a payer will allow?
The best way to determine the codes (CPT, ICD-10-CM and HCPCS) allowed by a payer is to review their payer policy. While it is good to know the official guidelines (e.g., ICD-10-CM Official Guidelines for Coding and Reporting, AMA Guidelines, Medicare ...
By Wyn Staheli, Director of Research | Published March 7th, 2019
Providers need to ensure that they are reporting radiology dates of service the way the payer has requested. Unlike other many other professional services which only have one date of service (DOS), radiology services can span multiple dates. Medicare requirements may differ from professional organization recommendations.
By Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content | Published March 1st, 2019
Medicare creates and maintains the National Correct Coding Initiative (NCCI) edits and NCCI Policy Manual, which identify code pair edits. When performed on the same patient, on the same day, and by the same provider, the secondary code is considered an integral part of the primary code, and payment for ...
Proposed Rule: Expanded Telemedicine Benefits for Medicare Advantage Beneficiaries
February 14th, 2019
By Aimee Wilcox | Published February 14th, 2019
Telemedicine continues its rise, with new technologies allowing for better communication and access to more aspects of healthcare than ever before. Each year Medicare has made strides, albeit small strides, in their telemedicine coverage while commercial payers continue to make great strides, constantly improving and expanding telemedicine service offerings to ...
Charging Missed Appointment Fees for Medicare Patients
February 7th, 2019
By Wyn Staheli, Director of Research | Published February 7th, 2019 - Last Review/Update February 8th, 2019
Some providers mistakenly think that they cannot bill a missed appointment fee for Medicare beneficiaries. You can, but Medicare has specific rules that must be followed. These rules are outlined in the Medicare Claims Policy Manual, Chapter 1, Section 30.3.13. You must have an official “Missed Appointment Policy” which is ...
Medicare Advantage Providers are not Required to be Enrolled in Medicare
December 18th, 2018
By Wyn Staheli, Director of Research | Published December 18th, 2018
There was a ruling that was requiring providers to be enrolled in Medicare in order to provide services for Part C (Medicare Advantage (MA)) and/or Part D. However, on April 2, 2018, CMS released the 2019 Final Rules for MA and Part D which changed this previous ruling. According to ...
By Wyn Staheli, Director of Research | Published December 18th, 2018
On December 14, 2018, the Office for Civil Rights (OCR) issued a Request for Information (RFI). They are considering making changes to some of the HIPAA regulations. Earlier this year at the HIMSS (Healthcare Information and Management Systems Society) meeting, Roger Severino, the head of the Office for Civil Rights ...
By NAMAS | Published December 7th, 2018 - Last Review/Update December 20th, 2018
Keeping up to date on coding and documentation changes, is critical for medical coders, billers, auditors, and compliance personnel. Every year American Medical Association (AMA) creates, revises, and deletes CPT codes on January 1st. Same thing occurs with the ICD-10 codes in October. For CPT codes, the intention of the...
Errors Billing Outpatient Services When Patient is also Inpatient
November 29th, 2018
By Wyn Staheli, Director of Research | Published November 29th, 2018
The OIG recently reported that Medicare inappropriately paid acute-care hospitals for outpatient services provided to patients who were inpatients of another facility including long term care hospitals, inpatient rehabilitation facilities, inpatient psychiatric facilities, and critical access hospitals. CMS suggests using the following resources to ensure compliance:
Medicare Inappropriately Paid Acute-Care Hospitals for ...
By Dr. Ray Foxworth, MCS-P, President of ChiroHealthUSA | Published November 28th, 2018 - Last Review/Update January 21st, 2019
You simply need to read the headlines, posts, and tweets, about providers across the healthcare profession being audited, fined, and some even convicted, to see that the costs of non-compliance are real. We tell ourselves, “It won’t happen to me.” The reality is that it easily could. Your license is your livelihood.
By BC Advantage | Published November 9th, 2018 - Last Review/Update November 29th, 2018
It seems like a simple code to bill, but CPT 99211 (established patient office visit) is by no means a freebie when it comes to documentation and compliance. This lowest level office visit code is sometimes called a "nurse visit" because CPT does not require that a physician be present...
Q/A: Does My LMT need an NPI? How do I Bill Her Services?
October 22nd, 2018
By Wyn Staheli, Director of Research | Published October 22nd, 2018 - Last Review/Update December 19th, 2018
Question:
I am setting up an LMT to work as employee under Dr. Clifton, DC. i need to know several things - hoping they are related and can be grouped into this one question.... does she need her own NPI? where does that NPI # go? what box #? if not, ...
By Wyn Staheli, Director of Research | Published September 28th, 2018
The OIG recently concluded an audit on a chiropractic office located in Florida and had some significant findings. They recommended the following:
Refund to the Federal Government the portion of the estimated $169,737 overpayment for claims for chiropractic services that did not comply with Medicare requirements and are within the 4-year ...
HIPAA Handling Patient Requests for Medical Record Restriction
September 26th, 2018
By BC Advantage | Published September 26th, 2018 - Last Review/Update October 17th, 2018
Healthcare compliance professionals frequently face confusing situations about sharing of protected health information (PHI). The Health Insurance Portability and Accountability Act (HIPAA) supports the protection of privacy of medical records. However, even when a patient does not authorize sharing of his record, there are permitted uses and disclosures, such as...
Finalized Confidentiality of Alcohol and Drug Abuse Patient Records Regulations
August 31st, 2018
By Wyn Staheli, Director of Research | Published August 31st, 2018
In January, the U.S. Department of Health and Human Services (HHS) issued updates to the privacy regulations regarding the confidentiality of patient information of substance use disorder patients (42 CFR Part 2). This notice included references to better alignment with HIPAA regulations, but did state that Part 2 is more protective ...
By Wyn Staheli, Director of Research | Published August 20th, 2018
Noridian's pilot program Provider Self-Audit with Validation and Extrapolation (PSAVE) has been extended which means that it has been successful for the payer, which means that they are saving money. Historically, when a pilot program is proven to be successful, it isn’t too long before other MACs follow. Before signing up to participate, providers need to carefully evaluate the program. Are the benefits worth the costs?
By BC Advantage | Published August 13th, 2018 - Last Review/Update September 24th, 2018
Incident-to services allow non-physician practitioners (NPPs) such as nurse practitioners and physician assistants to bill under a supervising physician if they perform services that are incidental to a physician-created plan of care. Incident-to billing offers two key benefits: First, the physician is reimbursed at 100% of the contracted rate with...
Attention Providers - Please Make Time to Read this Letter
July 17th, 2018
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published July 17th, 2018
In an effort to show CMS is committed to changing the rules to accommodate their providers CMS released a letter to Doctors of Medicare Beneficiaries. The letter offers encouragement and a promise to reduce the burden of unnecessary rules and requirements. The letter states “President Trump has made it clear that ...
By Wyn Staheli, Director of Research | Published July 12th, 2018
It is important to keep in mind that Medicaid is run at a state level so there can be some differences when it comes to coverage. However, the rules regarding balance billing of covered services is set at the federal level. The law states (emphasis added):
A state plan must provide ...
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published June 26th, 2018
Sooner or later ICD-11 will be released, and it sounds like it will be sooner than later. WHO released the news on June 18, 2018. The World Health Organization stated “ICD-11 will be presented at the World Health Assembly in May 2019 for adoption by Member States, and will come ...
Q/A: Can a PT Assistant Perform Physical Therapy Modalities?
June 18th, 2018
By Wyn Staheli, Director of Research | Published June 18th, 2018 - Last Review/Update January 30th, 2019
Whether or not a physical therapy assistant (PTA) may perform physical therapy modalities depends on two factors: state law and payer policies. Read here for more.
The Certificate of Medical Necessity (CMN) for Oxygen is a required form that helps to document the medical necessity for oxygen therapy. It also documents other coverage criteria for the oxygen use. For payment on a home oxygen claim, the information in the supplier’s records or the patient’s medical record must be substantiated with the information in the CMN.
Inappropriate Use of Units Costs Practice Over $800,000
June 11th, 2018
By Wyn Staheli, Director of Research & Aimee Wilcox, CPMA, CCS-P, CMHP, CST, MA, MT | Published June 11th, 2018
A recent OIG enforcement action emphasizes the need to understand the proper use of units. A healthcare provider in Connecticut improperly submitted multiple units for drug screening urine tests. The proper billing of units has proven to be problematic for more than just lab tests. Is your billing of drugs & biologicals, injections and timed codes appropriate?
By Gregg Friedman, DC, CCSP | Published June 7th, 2018 - Last Review/Update January 30th, 2019
As both a chiropractor for 31 years and one who reviews a lot of medical records for the medicolegal arena and has been teaching documentation for many years, the range of motion question comes up frequently. Although we used to get reimbursed very well for a specific range of motion code back in ...
By Sean M. Weiss & Frank Cohen | Published May 30th, 2018 - Last Review/Update June 4th, 2018
This year (2018), healthcare organizations (Hospitals, Health Systems, and Physician Groups/Practices) must focus on the criticality of creating a culture of compliance to ensure effectiveness and efficiency. Focusing on "compliance"-only approaches leaves healthcare organizations exposed to areas of liability oftentimes far more than what they could ever imagine or even...
By Linda Walker | Published May 30th, 2018 - Last Review/Update June 4th, 2018
Medical billers often encounter the dilemma of a physician who wants to be the hero to his or her patients and waive their out-of-pocket expenses. Out-of-pocket expenses include a patient's co-payment, coinsurance, deductibles, charges above U&C (Usual and Customary), and even services a plan may not cover in some situations....
By Rachel V. Rose, JD, MBA | Published May 30th, 2018 - Last Review/Update June 4th, 2018
Whether I am assisting clients or presenting, I am often asked about legal holds and e-discovery. The transition from paper to electronic records, which include emails, computer faxes, protected health information ("PHI"), personally identifiable information ("PII") and documents that are created, received, maintained or transmitted in an electronic format created...
Q/A: How Do I Respond to a Patient's Request to Not Submit the Claim to Their Insurance?
May 7th, 2018
By Wyn Staheli, Director of Research | Published May 7th, 2018 - Last Review/Update January 30th, 2019
A number of patients now have high deductible plans. Sometimes, deductibles can be $5000 or $10,000. My payer contract states that I must submit all claims to insurance for covered services. However, sometimes patients with these high deductibles come to my office and state that they would prefer to receive a modest discount for paying cash and in turn, not have their services submitted to insurance. As a doctor, this places me in a tough situation. Do I follow the patient's wishes or the payer contract?
By J. Paul Spencer, CPC, COC | Published May 4th, 2018 - Last Review/Update May 24th, 2018
As an auditor who has reviewed thousands and thousands of encounter documents for level of service, a predictable pattern has merged when it comes to the Medical Decision Making (MDM) component that has attracted my attention.
By Wyn Staheli, Director of Research | Published April 30th, 2018 - Last Review/Update January 30th, 2019
As chiropractors we feel the new modifier 97 is more appropriate than 96 for our PT codes such as stim and traction. Yet Carefirst is asking for 96 only. Should we use this code on all the PT codes and for all the other insurance companies?
Q/A: Someone Broke into My Office. What do I do Now?
April 23rd, 2018
By Wyn Staheli, Director of Research | Published April 23rd, 2018 - Last Review/Update January 24th, 2019
My office was broken into last night. I use electronic health records, but we do store some protected health information for my patients in paper files. These files are not secured, so the burglars did have access to them. It did not appear that the files were touched as the burglars were looking for cash. What responsibilities to I have to my patients in a situation like this? Do I need to contact them and advise them that their PHI could have been compromised?
The PSAVE Pilot Program: Should You Self-Audit Your Medicare Claims?
April 20th, 2018
By Robert Liles, JD, MBA, MS | Published April 20th, 2018 - Last Review/Update April 25th, 2018
As the Medicare program has grown, the Centers for Medicare and Medicaid Services (CMS) has employed a variety of different claims audit mechanisms to better ensure that the Medicare Trust Fund is protected from waste, fraud and abuse....
By Christine Woolstenhulme, QCC, CMCS, CPC, CMRS | Published April 9th, 2018
Since the publication of the Compliance Program Guidelines in 2012, the Medicare Part C & D Oversight and Enforcement Group, Division of Compliance Enforcement, has presented a series of focused trainings for the industry on the application of the seven elements of an effective compliance program. These trainings are designed ...
By Shannon DeConda, CPC, CPC-I, CEMC, CEMA, CPMA, CRTT | Published February 2nd, 2018 - Last Review/Update February 7th, 2018
This week we had a great question posted to our online forum, and I thought it would be a nice thought- provoking question for our auditing and compliance tip of the week.
By Wyn Staheli, Director of Research | Published February 1st, 2018
On January 16, 2018, the OIG released a report of their findings on claims data for Medicare Advantage plans. While it appears that there were not significant issues, they did find that:
"Types of potential errors included inactive or invalid billing provider identifiers; duplicated service lines; missing required data; inconsistent dates; ...
By Marge McQuade, CMSCS, CHCI, CPOM | Published January 31st, 2018
Every physician practice depends upon correct coding and billing for their financial success. Coding drives reimbursement. All of the resources available for coding information and guidance are meaningless without the practice manager translating it into provider-specific coding policies and compliance plan. As a practice manager, you need to develop a ...
Dental and Medical- Controlled Substance Awareness
January 29th, 2018
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published January 29th, 2018
As an effort to cut down on opioid abuse and related crimes, in August of 2017 the Attorney General Sessions established a new Department of Justice (DOJ) section called “Opioid Fraud and Abuse Detection Unit”. Due to the serious public health issue and drug overdose deaths, this unit was established and ...
By Sean M. Weiss, CHC, CEMA, CMCO, CP MA, CPC-P, CMPE, CPC | Published January 26th, 2018 - Last Review/Update February 7th, 2018
This year (2018), health care organizations (Hospitals, Health Systems and Physician Groups/Practices) must focus on the criticality of creating a culture of compliance to ensure effectiveness and efficiency....
NEW on Find-A-Code...National Coverage Determinations (NCDs)
January 23rd, 2018
By Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content | Published January 23rd, 2018 - Last Review/Update January 25th, 2018
Medicare limits its coverage of services to those considered to be reasonable and necessary for the diagnosis and treatment of an injury or illness based on coverage guidelines. National Coverage Determinations (NCDs) are created based on research, evidence-based processes, public participation, and other resources, and made available to the public. ...
By Wyn Staheli, Director of Research | Published January 16th, 2018
Section 1848(r)(4) of MACRA requires that claims submitted for items and services furnished by a physician or applicable practitioner on or after January 1, 2018, include codes for the following:
care episode groups
patient condition groups
patient relationship categories
Previously, CMS decided to use procedure code modifiers to report patient relationship codes on Medicare ...
By Wyn Staheli, Director of Research | Published January 2nd, 2018 - Last Review/Update January 30th, 2019
I checked the government website to see if I am an eligible clinician and it says that I am not. I just don't want to get blindsided with a letter saying I will be penalized. Is there anything you would suggest or recommend that I do now to protect myself from future penalties. Thank you
By Wyn Staheli, Director of Research | Published December 21st, 2017
In the compliance world, it is important to know when the OIG makes an advisory opinion on a subject. For example, the advisory on Time of Service or Prompt Pay Discounts helps to ensure that providers are creating policies and procedures which will meet the standards of the OIG in the case ...
By Marge McQuade CMSCS, CHCI, CPOM | Published December 12th, 2017
The financial health of every medical practice rests upon correctly coded claims. This is true from not only a financial standpoint since coding drives reimbursement, but from a compliance perspective as well. All of the resources available for coding information and guidance are meaningless without the practice manager sifting through...
Can an Unlicensed Person Perform Physical Therapy Services Such as 97110?
November 16th, 2017
By Wyn Staheli, Director of Research | Published November 16th, 2017 - Last Review/Update January 30th, 2019
Can an unlicensed person perform code a 97110 service as long as they're under doctor supervision? I use only PT, ATC, or DC's to perform these codes and I've been told that I don't need such highly qualified therapists to perform therapy.
By Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP | Published October 23rd, 2017
The Office of the Inspector General was created to protect the integrity of the U.S. Department of Health and Human Services. They investigate fraud, waste, and abuse in HHS programs and make recommendations to various enforcement agencies. Every few years they investigate chiropractic services. Here is a summary of the reports the ...
By Brandy Brimhall, CPC CPCO CMCO CPMA QCC | Published October 13th, 2017 - Last Review/Update February 5th, 2019
Chiropractors cannot opt-opt of Medicare. Does that only refer to chiropractors that see Medicare patients? Do all Florida chiropractors have to complete Medicare enrollment/credentialing? Bottom line- do ALL chiropractors, no matter where or who, have to complete Medicare enrollment since they cannot Opt-out?
Your NAMAS Weekly Auditing & Compliance Tip for October 6, 2017
October 6th, 2017
By NAMAS | Published October 6th, 2017 - Last Review/Update October 16th, 2017
October 6, 2017
Acronyms and Abbreviations: When You Fall Into The Grey Area
We've all been there... you are coding or auditing, and then a note comes up that is not like the ones you've reviewed before.
The language is unclear, the acronym(s) could mean so many different things, and it's hard to get ...
Double Dipping in the History of the Evaluation and Management Note
September 14th, 2017
By Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content | Published September 14th, 2017
There are many rules and guidelines a coder must be aware of when it comes to appropriately selecting an Evaluation and Management (EM) code and avoiding doubling dipping is one of them. Double dipping occurs when the same information is used in more than one of the subcomponents of history.
The subcomponents of history include:
Chief Complaint ...
Medicare Improper Payment Report for Chiropractic (2016)
September 1st, 2017
By Wyn Staheli, Director of Research | Published September 1st, 2017 - Last Review/Update October 16th, 2017
The Medicare Improper Payment Report for 2016 has been released by the OIG. Please note that the improper payment rate does not measure fraud. Rather, it estimates the payments that did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from ...
Medicare Improper Payment Report for Behavioral Health Services (2016)
September 1st, 2017
By Wyn Staheli, Director of Research | Published September 1st, 2017 - Last Review/Update October 16th, 2017
The Medicare Improper Payment Report for 2016 has been released by the OIG. Please note that the improper payment rate does not measure fraud. Rather, it estimates the payments that did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from ...
By Wyn Staheli, Director of Research | Published September 1st, 2017 - Last Review/Update October 16th, 2017
The Medicare Improper Payment Report for 2016 has been released by the OIG. Please note that the improper payment rate does not measure fraud. Rather, it estimates the payments that did not meet Medicare coverage, coding, and billing rules. The estimated Medicare FFS payment accuracy rate (claims paid correctly) from ...
Q/A: What are the Rules for a Fill-in (locum tenens) Doctor?
August 17th, 2017
By Brandy Brimhall, CPC CPCO CMCO CPMA QCC | Published August 17th, 2017 - Last Review/Update February 5th, 2019
A locum tenens provider is one that works in the place of the regular physician for a short duration of time. Guideline typically allows this time period to be a 60 day maximum, when a substitute doctor would be brought in to your office to cover your original doctor's actual schedule during the time he/she is absent.
Read further for more information
By Wyn Staheli, Director of Research | Published August 4th, 2017
An article by Medical Economics highlights the June report of the Health Care Industry Cybersecurity Task Force. Their report confirmed once again that healthcare providers are not adequately addressing cybersecurity as part of the compliance programs. The threat of hackers is very real and providers need to ensure that they have taken ...
By now, hopefully most (if not all) practices know that the Office of Inspector General (OIG) has been stressing the importance of creating and abiding by a compliance plan for most of this decade. In its own words, the OIG believes "that a healthcare provider can use internal controls to ...
By Dr. Mario Fucinari, Author & Member of the Carrier Advisory Committee for Medicare | Published June 28th, 2017 - Last Review/Update February 8th, 2019
Identity theft has become a major problem in the United States. As a prevention measure, the Centers for Medicare& Medicaid Services (CMS) is readying a fraud prevention initiative that removes Social Security numbers from Medicare cards to help combat identity theft, and safeguard taxpayer dollars.
Office of Inspector General (OIG) - Compliance Program Guidance
April 14th, 2017
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published April 14th, 2017
The compliance program guidance documents are listed below.
09-30-2008Supplemental Compliance Program Guidance for Nursing Facilities (73 Fed.Reg. 56832; September 30, 2008)
Compliance Program Guidance for Nursing Facilities (65 Fed. Reg. 14289; March 16, 2000)
11-28-2005Draft Compliance Program Guidance for Recipients of PHS Research Awards (70 Fed.Reg. 71312; November 28, 2005)
NSTC Launches Government-Wide Initiative ...
By Wyn Staheli, Director of Research | Published April 10th, 2017
On February 3, 2017, the Department of Justice (DOJ) issued a Final Rule to increase the civil monetary penalties assessed under the False Claims Act (FCA), due to inflation for the year 2017, to an all-time high of $10,957 (minimum) to $21,916 (maximum). Thirty years ago, in 1986, Congress amended the False ...
How to Properly Dispose Protected Health Information (PHI)
February 27th, 2017
By InstaCode Institute | Published February 27th, 2017
HIPAA requires covered entities to properly dispose of Protected Health Information (PHI) in the following manner:
Paper, film, or other hard copy media has been shredded or destroyed such that the PHI cannot be read or otherwise cannot be reconstructed.
Electronic media has been cleared, purged, or destroyed consistent with NIST Special Publication 800-88, Guidelines for Media ...
By Wyn Staheli, Director of Research | Published February 23rd, 2017
In June 2015, the Office of Inspector General (OIG) issued a Fraud Alert focused on physicians and compensation arrangements. Providers need to ensure that these arrangements do not violate the Anti-Kickback Statute. Healthcare providers found to have committed fraud are subject to possible criminal, civil and administrative sanctions.
In this alert ...
By Wyn Staheli, Director of Research | Published February 23rd, 2017
All federal healthcare programs are required to implement programs to prevent and reduce provider fraud, waste, and abuse and this includes the Medicaid program. Two groups work in conjunction with the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General (OIG):
the Medicaid Integrity Program (MIP) works at ...
By Wyn Staheli, Director of Research | Published February 23rd, 2017
Compliance has a new standard for emergency preparedness plans. On September 8, 2016, CMS issued the final rule titled “Emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers.” This rule creates emergency preparedness Medicare Conditions of Participation (COPs).
There are specific standards for each of the named types of providers ...
By Evan M. Gwilliam, DC MBA BS CPC CCPC CPC-I QCC MCS-P CPMA CMHP | Published January 23rd, 2017 - Last Review/Update February 8th, 2019
Generating a differential diagnosis — that is, developing a list of the possible conditions that might produce a patient's symptoms and signs — is an important part of clinical reasoning. It allows a provider to perform appropriate testing to rule out possibilities and confirm a final diagnosis.
Courts view the formulation and documentation of a differential diagnosis as evidence of a physician's competence, prudence, and thoughtfulness.
By Wyn Staheli, Director of Research | Published December 19th, 2016
Benchmarking is simply a standard or point of reference against which things may be compared or assessed. For all businesses, it is a way of comparing your business processes to another business in the same industry to determine where shortfalls exist or improvements can be made to maintain profitability.
By Wyn Staheli, Director of Research | Published December 12th, 2016
Effective March 14, 2016, the CMS Final Rule clarifying the standards for handling
overpayments for both Medicare and Medicaid takes effect. Failure to report and
subsequently return an overpayment within 60 days after the overpayment was
“identified” is a violation of the False Claims Act.
Have you ever read a physician office note and thought it was strangely familiar? Or, not just familiar but identical to another note? Well, Medicare contractors have noticed the same thing, and the Office of Inspector General has included this on their 2011 Work Plan. Medicare contractors have noted an...
Are the following statements true or false? • The PCP cannot be paid to do a pre-op assessment of a Medicare patient prior to surgery because of the new consult rules. • The surgeon can never be paid to do a pre-op visit if s/he is going to take the...
OIG adds to increased scrutiny of how patients pay for rising share of drug costs
July 28th, 2016
By | Published July 28th, 2016
Charity programs that help patients pay for the rising cost-sharing obligations of needed drugs may run afoul of anti-kickback rules when the charity’s scope is so narrow that it guides the patient toward specific drugs for treatment or providers, the HHS Office of Inspector General said last week.The OIG’s Supplemental...
OIG Work Plan to look at excessive patient billing, place of service errors
July 28th, 2016
By | Published July 28th, 2016
The 2014 OIG Work Plan has finally been released and, while it doesn’t have a lot of new issues for physician practices, there are definitely some areas worth your attention to avoid future compliance hassles. If you’ve been wondering where it’s been, the OIG decided to change the timing of...
OIG Work Plan 2012-Do your own review of these areas
July 28th, 2016
By | Published July 28th, 2016
The Office of Inspector General released its Work Plan for 2012. As in past years, the Work Plan describes the areas of interest that the OIG will investigate in the coming year. There are sections for hospitals, nursing homes, and of course, physicians. There is a pdf file attached to...
By Wyn Staheli, Director of Research | Published June 21st, 2016
When a claim has been determined to be paid more than the allowed amount, it is considered an overpayment. The action to be taken depends on how the overpayment is discovered. This article covers voluntary overpayment refund procedures as well as a Voluntary Overpayment Form.
Q&A: Will Using Lower Level Codes Reduce Our Chances of Being Audited?
June 16th, 2016
By ChiroCode | Published June 16th, 2016 - Last Review/Update March 5th, 2019
Q&A: If we use low level codes on each visit (such as 98940, 99212, 99202), will our chances of being audited be less than if we billed higher level codes?
Mastering Medicare: When Opting Out is not an Option
June 15th, 2016
By Dr. Ray Foxworth, Certified Medical Compliance Specialist and President of ChiroHealthUSA | Published June 15th, 2016 - Last Review/Update March 5th, 2019
Unlike MDs and DOs, chiropractors may not opt out of Medicare.
When it comes to Medicare, providers and patients alike feel like beating their heads against the wall. Signing up to be a provider or a patient is confusing, understanding what is covered is confusing and just about the time you think you have it figured out, you receive a notice that suggests you don’t.
The hassles of Medicare certainly validate any sane person questioning whether they should see a Medicare patient, but with the rising number of Medicare patients in the US do you really want to limit your patient base?
By Dr. Ray Foxworth, Certified Medical Compliance Specialist and President of ChiroHealthUSA | Published May 26th, 2016 - Last Review/Update March 5th, 2019
Our team is frequently asked if it is legal for chiropractic offices to offer coupons or Groupons. We’re not allowed, as a profession, to dramatically discount our services, offer free treatments, or provide gifts or free meals for potential patients. Any one of these things can be considered an “inducement.” Practices that improperly induce patients to seek care or services, for example, by providing coupons for care or supplies, may find that they are in violation of the law if they aren’t careful.
So what will that mean to you and your practice? It isn’t pretty.
Your Reasons to Delay Compliance Implementation are GONE!
May 19th, 2016
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published May 19th, 2016
ChiroCode has proudly served chiropractic for more than 30 years and continues to work to bring the most necessary, affordable, and user friendly products and services to practices. Increased regulation has hindered practices by creating uncertainty around the nature of guidelines and the expensive penalties that arise from non-compliance with ...
An Important Rule that You're Probably Not Following
April 28th, 2016
By ChiroCode | Published April 28th, 2016 - Last Review/Update March 5th, 2019
The HIPAA Security Rule requires that covered entities (your practice) conduct a Security Risk Assessment (SRA) for your organization, at a minimum of once per year. It is critical that practices perform the Security Risk Assessment for multiple of reasons. Not only is it important to comply with rules and regulations, but also, for what you may consider to be a more motivational reason, to protect your practice (and bank account) from what could become disabling fines and penalties.
Lack of Business Associate Agreement (BAA) Costs Non-Profit 1.55 Million
April 13th, 2016
By Wyn Staheli, Director of Research | Published April 13th, 2016
Failure to have a properly executed Business Associate Agreements (BAA) costs one organization $1.55 Million. In today's highly technological environment, it is too easy to skip the necessary precautions and easy for electronic devices to get lost or stolen. Are you prepared?
By Instacode Institute | Published April 6th, 2016
It's not just the names and addresses that matter -- It's the compliance. If you can demonstrate that you are hleping yourself to maintain HIPAA compliance by careful documentation and proper procedures, you can go a long way toward avoiding being fined by the HIPAA squads.
Complete & Easy HIPAA Compliance is a clear, simple “Just help me do what I have to do!” workbook that contains all the things the designated security officer must do to instantiate a robust HIPAA compliance program. It comes complete with over 45 forms and letters which can be used to state the office policies, spell out procedures, and ensure that each patient will be protected in their rights under HIPAA policy. It also can help demonstrate that a compliance program is in progress.
Occasionally providers are faced with the need to assess the option of making a voluntary disclosure to the government. Here are steps that every provider should consider before disclosing information to the government.
Protected Health Information De-Identification Standards
March 16th, 2016
By Instacode Institute | Published March 16th, 2016 - Last Review/Update January 27th, 2017
This article contains detailed information on the OCR guidance regarding the de-identification of Protected Health Information (PHI). Avoid HIPAA violations and learn specifically what de-identification is.
By Sara San Pedro, CPC, CEMC, CPMA | Published March 4th, 2016
NAMAS Weekly Auditing and Compliance Tips Modifier 24 (Unrelated Evaluation and Management Service by the Same Physician during a Postoperative Period) has generated more scrutiny lately because of the attention it is receiving from Recovery Auditors and payors. An assignment of modifier 24 will oftentimes trigger a medical record...
Employee Exclusions Screenings Must be High Priority
February 24th, 2016
By Wyn Staheli | Published February 24th, 2016
Many healthcare organizations are not aware of how critically important it is to screen their employees against ALL state and federal exclusions databases. This article has important information for organization to ensure compliance.
By InstaCode Institute | Published February 15th, 2016
CMS is developing a new Unified Program Integrity Contractor (UPIC) program to consolidate Medicare and Medicaid reviews. This consolidation of the Medicaid Integrity Contractors (MICs) and the Medicare Zone Program Integrity Contractors (ZPICs) could relieve some of the overlap and burdens under the current systems.
What are the Rules for Safeguarding Patient Records?
February 11th, 2016
By ChiroCode | Published February 11th, 2016 - Last Review/Update March 5th, 2019
Secure medical records is a broad topic that should be addressed in detail by all practices. There are multiple items to consider when meeting standards to best safeguard protected health information (PHI).
Will Incident-To in Your Organization Pass a Compliance Audit?
February 1st, 2016
By Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content | Published February 1st, 2016
Practices that bill incident to services need to periodically audit compliance with Medicare and private payor guidelines to avoid potential denials or third-party audits.
The past year has been an exciting time for healthcare professionals, bringing more changes, opportunities and challenges than ever before. The Health Information Technology for Economic and Clinical Health (HITECH) Act, which is a portion of the American Recovery and Reinvestment Act of 2009,...
By Aimee Wilcox, MA CST CCS-P | Published December 21st, 2015
If your organization performs incident-to services, be sure to perform a periodic review of the rules that govern incident to and then compare them to the practices of your providers to ensure they would pass an audit. Here are just a few of the guidelines that should be reviewed; however, ...
By InstaCode Institute | Published November 9th, 2015
Many healthcare providers are unaware that they are obligated to adhere to all OSHA rules and regulations relevant to their place of business. This includes safety plans and reporting of injuries. New record keeping rules went into effect on January 1, 2015. As part of the new ruling, an online reporting ...
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published August 19th, 2015
Q: Our office has recently had to let an employee go that had been here for a long period of time. What would you recommend to us to ensure we have handled this properly?
A: Not having any information of the circumstances, here are a few general recommendations for you to ...
Chiropractic Listed as Focal Point in 2015 OIG Work Plan
August 19th, 2015
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published August 19th, 2015 - Last Review/Update January 30th, 2017
With the recent release of the 2015 OIG Work Plan, many providers and facilities are reviewing the content to learn which areas of interest pertaining to their specialty will be points of interest for federal auditing programs for the 2015 Fiscal Year. The information contained in this Work Plan addresses the ...
By ChiroCode | Published August 10th, 2015 - Last Review/Update January 27th, 2017
The following are some of the acronyms you would need to know when communicating with auditors:
National Correct Coding Initiative (NCCI) Edits: Use of codes that should not occur on the same day, effectively treating the same area twice.
Medically Unlikely Edits (MUE): Exceeding the anticipated units of service (time spent) for a given HCPCS or CPT code.
Office of the ...
Appointments, Reminders, Text Messaging, and HIPAA
August 10th, 2015
By ChiroCode | Published August 10th, 2015 - Last Review/Update January 27th, 2017
As more and more people are using mobile and wireless devices, a new term - mHealth - has emerged. According to a National Institute of Health consensus group, mHealth is “the use of mobile and wireless devices to improve health outcomes, healthcare services and health research.” Historically, the biggest gaps and HIPAA violations have been linked to ...
By Dr. Chris Andersn | Published April 24th, 2015 - Last Review/Update June 9th, 2016
Compliance is an issue that you should look at as an expedition rather than an endpoint. Board complaints can be a terrifying ordeal, especially if you don’t keep up on compliance in your clinic. Board complaints are something that you have to expect to happen but you can turn that ...
G0105 - Colorectal Cancer Screening; Colonoscopy on Individual at High Risk
April 9th, 2015
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published April 9th, 2015 - Last Review/Update August 8th, 2017
Screening colonoscopies (code G0105) may be paid when performed by a doctor of medicine or osteopathy at a frequency of once every 24 months for beneficiaries at high risk for developing colorectal cancer (i.e., at least 23 months have passed following the month in which the last covered G0105 screening colonoscopy was performed). ...
By ChiroCode | Published February 26th, 2015 - Last Review/Update January 27th, 2017
Recently, the U.S. Department of Health and Human Services Office of Inspector General updated their booklet, “Avoiding Medicare and Medicaid Fraud and Abuse.”
In this publication, the Government agencies, including the Department of Justice, the Department of Health and Human Services office of Inspector General, and the Centers for Medicare and ...
By Wyn Staheli, Director of Research | Published February 9th, 2015 - Last Review/Update June 9th, 2016
How secure is your computer? Do you have a password on your computer? Do you have the automatic log offs turned on? Is your computer encrypted? Are your off-site storage files encrypted?
This document is designed to give some basic information about making your office a little more secure. It is not ...
By | Published February 3rd, 2015 - Last Review/Update June 9th, 2016
The following information (emphasis added) is from: http://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/aca_implementation_faqs15.html
Provider Non-Discrimination PHS Act section 2706(a), as added by the Affordable Care Act, states that a “group health plan and a health insurance issuer offering group or individual health insurance coverage shall not discriminate with respect to participation under the plan or coverage against ...
Chiropractic Listed as Focal Point in 2015 OIG Work Plan
January 23rd, 2015
By | Published January 23rd, 2015 - Last Review/Update January 30th, 2017
With the recent release of the 2015 OIG Work Plan, many providers and facilities are reviewing the content to learn which areas of interest pertaining to their specialty will be points of interest for federal auditing programs for the 2015 Fiscal Year. The information contained in this Work Plan addresses ...
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published January 9th, 2015 - Last Review/Update January 30th, 2017
Conducting a job interview for potential new employees is a common occurrence, yet is often done in a manner of disorganization. Employers are frequently asking questions that shouldn't be asked and neglecting to ask those questions that may be more essential for conducting a proper interview. Federal and state laws ...
By | Published December 30th, 2014 - Last Review/Update March 9th, 2016
Time-of-Service (TOS) discounts are a common occurrence in chiropractic. What is often assumed is that if insurance isn't involved, there are no rules that apply.
Unfortunately, this is a myth that can become costly to practices and damage provider/patient relationships. So read on to learn the facts about TOS discounting and ...
Compliance Program - What are the Requirements to Implement an Effective Program
December 19th, 2014
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published December 19th, 2014 - Last Review/Update March 1st, 2016
All sponsors are required to adopt and implement an effective compliance program,which must include measures to prevent, detect and correct Part C or D program noncompliance as well as FWA.
The compliance program must, at a minimum, include the following core requirements:
1. Written Policies, Procedures and Standards of Conduct;
2. Compliance ...
OIG Reports Success in Efforts to Prevent Fraud, Waste, and Abuse
December 15th, 2014
By | Published December 15th, 2014 - Last Review/Update January 30th, 2017
The HHS OIG Work Plan for the 2015 Fiscal Year has recently been released. In this publication, the OIG addresses the accomplishments made from the previous year's Plan as well as the objectives that will be of interest for the coming new year. Accomplishments for the 2014 Fiscal Year are ...
OASIS Data to be Submitted via Assessment Submission and Processing (ASAP) System Effective Jan 1, 2015
December 4th, 2014
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published December 4th, 2014 - Last Review/Update March 1st, 2016
Effective January 1, 2015, OASIS assessment data will be submitted to CMS via the national OASIS Assessment Submission and Processing (ASAP) system. With the implementation of the OASIS ASAP system, Home Health Agencies will no longer submit OASIS assessment data to CMS via their state databases. To access the ...
Establishing a Multi-Disciplinary Practice and Being Legal
November 21st, 2014
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 21st, 2014 - Last Review/Update January 30th, 2017
Q: How do you add another provider type such as a Nurse Practitioner to your practice to provide additional services to patients and legally bill for those services under their license?
A: Multi-disciplinary practices are under scrutiny at the moment by ZPIC, CMS and State Boards. For your reference, just below, there ...
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 19th, 2014 - Last Review/Update January 30th, 2017
Each new year brings a bundle of surprises in terms of changes and updates that practices must learn and implement. In effort to aid in the preparation of this year, I have listed some common helpful tips that you might follow in order to best manage your workload ahead.
-Evaluate fees:Â Fee ...
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 19th, 2014 - Last Review/Update January 30th, 2017
The following chart identifies each of the 7 zones for ZPIC and the states/regions within each zone.  Links are provided for each zone which contains information about each zone as well as activity and updates in those regions.Â
ZPIC
Zone
States in Zone
Safeguard Services (SGS)
1
California, Hawaii, Nevada, American Samoa, Guam, Mariana Islands
Health Integrity
(subcontractor ...
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 19th, 2014 - Last Review/Update January 30th, 2017
Recovery Audit Contractors, also known as RAC, is a program that seeks to identify and correct improper payments for services provided to Medicare Parts A & B beneficiaries. This includes both recoupment of overpayments and corrected distribution of underpayments made by CMS.  RAC began in 2005 as a three-year demonstration project consisting ...
Conducting a Gap Analysis for Your Documentation & Billing Systems
November 17th, 2014
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 17th, 2014 - Last Review/Update January 30th, 2017
What is a Gap Analysis?
A Gap Analysis is a process by which a practice conducts a baseline assessment of the company's coding, billing, operations, and business practices. The objective of a Gap Analysis is to ensure that the practice is in full compliance with applicable legal and ethical requirements. This ...
Social Media and Healthcare: Unprofessional Conduct and What It Can Cost
November 17th, 2014
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published November 17th, 2014 - Last Review/Update January 30th, 2017
In this electronic age, Social Media has quickly become a very successful tool used for advertising/marketing, communication of various topics and reaching readers and networks beyond our wildest dreams. These networks are often leading to various opportunities or other positive occurrences that we may not have otherwise experienced. Social Media ...
By Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP | Published October 24th, 2014 - Last Review/Update January 30th, 2017
Straight from the Office of Civil Rights:
Q: Does the HIPAA Privacy Rule permit health care providers to use e-mail to discuss health issues and treatment with their patients?
A: Yes. The Privacy Rule allows covered health care providers to communicate electronically, such as through e-mail, with their patients, provided they apply ...
By Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP | Published October 16th, 2014 - Last Review/Update January 23rd, 2017
In October of 2000 in the Federal Register the Office of the Inspector General (who investigates fraud against the federal government on behalf of the Department of Health and Human Services) offered general guidelines for health care facilities to set up a “Compliance Program”. This advice has long been pushed ...
The Role of Statistical Analysis in Fighting Fraud
October 16th, 2014
By Jared Staheli | Published October 16th, 2014 - Last Review/Update January 30th, 2017
It is common knowledge that fraud is a large problem for payers, who must spend money paying fraudulent claims as well as on recovery. New developments in statistical analysis helps to combat this.
OSHA - Hazard Communication Standard Final Rule (Globally Harmonized System)
October 6th, 2014
By | Published October 6th, 2014 - Last Review/Update January 30th, 2017
The Hazard Communication Standard in 1983 gave workers the "right to know," but the new Globally Harmonized System gives workers the "right to understand."
What you need to do and when:
Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and ...
By | Published October 3rd, 2014 - Last Review/Update January 27th, 2017
A “good” lawyer could be a “bad” lawyer when it come to your unique problem(s). Never ask or expect any professional person (doctor or lawyer) to perform beyond their scope of practice or ability. A college law degree and passing the state bar, is only a license which permits them ...
OSHA- Hazard Communication Standard Final Rule (Globally Harmonized System)
October 2nd, 2014
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published October 2nd, 2014 - Last Review/Update January 30th, 2017
The Hazard Communication Standard in 1983 gave workers the "right to know," but the new Globally Harmonized System gives workers the "right to understand."
What you need to do and when:
Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and ...
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published September 26th, 2014 - Last Review/Update January 30th, 2017
MEASURE COMPLIANCE - Meeting the Patient Electronic Access Objective
Starting in 2014, CMS requires that providers participating in both Stage 1 and Stage 2 of the EHR Incentive Programs must meet the Patient Electronic Access objective, which gives patients access to their health information in a timely manner. Providers participating in ...
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published September 25th, 2014 - Last Review/Update January 30th, 2017
Enforcement Actions in FY 2013: the Department of Justice (DOJ) opened 1,013 new criminal health care fraud investigations involving 1,910 potential defendants. Federal prosecutors had 2,041 health care fraud criminal investigations pending, involving 3,535 potential defendants, and filed criminal charges in 480 cases involving 843 defendants. A total of 718 ...
According to HIPAA, who are my Business Associates?
September 11th, 2014
By Brandy Brimhall, CPC, CMCO, CCCPC, CPCO, CPMA | Published September 11th, 2014 - Last Review/Update January 30th, 2017
Providers work with many different groups and many of them have some interaction with Protected Health Information (PHI). In an effort to help us understand who qualifies as Business Associates the Department of Health & Human Services has provided some resources.
But first … what is PHI or individually identifiable health information? ...
Compliance specialists are responsible for monitoring health and human services program operations for compliance with federal and state regulations and standards in order to promote health and safety, assure that public services are delivered properly, or prevent fraud. Areas assessed may include service delivery, eligibility determination and payment, medical reimbursement, ...
By Chris Woolstenhulme, QCC, CMCS, CPC, CMRS | Published August 29th, 2014 - Last Review/Update January 30th, 2017
The associates in the provider’s world and healthcare society are filled with loads of potential business associates and endless Individual identifiable health information.
 We have had so many questions about business associates I thought I would go to the source and put together some information from HHS.gov, otherwise known as U.S. ...
By Wyn Staheli, Director of Research | Published May 28th, 2014 - Last Review/Update January 25th, 2017
This article contains information from OSHA which outlines the penalty structure for OSHA violations. It includes a list of different types of violations that may be cited and the penalties that may be proposed by the area director. Also listed are additional violations for which citations and proposed penalties may be issued upon conviction.
These are the types of violations that may be cited and the penalties that may be proposed
How can I make sure new hires have not been in trouble with Medicare?
March 18th, 2014
By Christopher Anderson, DC MCS-P | Published March 18th, 2014 - Last Review/Update January 25th, 2017
To avoid liability, it is recommended to routinely check (every 3 months) the LEIE to ensure that new hires and current employees are not on the excluded list.
One of the many parts of the compliance program is to see if your current staff (including yourself, regular staff and associate doctors) have been placed on the OIG (Office of the Inspector General) List of Excluded Individuals and Entities (LEIE).
OIG has the authority to exclude individuals and entities from Federally funded health care programs and maintains a list (List of Excluded Individuals and Entities or LEIE)of all currently excluded individuals and entities. Anyone who hires an individual or entity on the LEIE may be subject to monetary penalties.
It’s as simple as 1…2…3..
Read More
By | Published February 19th, 2014 - Last Review/Update January 27th, 2017
As more and more people are using mobile and wireless devices, a new buzzword has emerged: mHealth. According to a National Institute of Health consensus group, mHealth is "the use of mobile and wireless devices to improve health outcomes, healthcare services and health research." Historically, the biggest gaps and HIPAA violations ...
By | Published February 12th, 2014 - Last Review/Update January 27th, 2017
The following information is from the Centers for Medicare & Medicaid Services (CMS) regarding the Electronic Health Records (EHR) payment reduction hardship exemption.
By | Published September 30th, 2013 - Last Review/Update January 27th, 2017
September 23rd, 2013 was the deadline for HIPAA Omnibus Final Rule compliance. It seems to have just snuck up on everybody. ChiroCode has spoken with some clincis who say that they don't need to worry about it because ”they are just a small practice.” Please, do not wait any longer to ...
By | Published September 24th, 2013 - Last Review/Update January 27th, 2017
Be aware of the possible monetary results and enforcement actions imposed for fraud. This is the annual report of the Department of Justice Health Care Fraud and Abuse Control Program for FY 2012
By | Published September 6th, 2013 - Last Review/Update January 27th, 2017
The official deadline for HIPAA covered entities to reach compliance with the provisions of the Omnibus Rule is officially set as September 23, 2013. This date is right around the corner and as a result, providers are concerned about meeting this deadline. The definition for a business associate has been ...
A simple and practical guide to implementing HIPAA, HITECH, and Omnibus Final Rule components. Includes the forms and policies and information you need to meet compliance requirements. Plus over 50 customizable forms!
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