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"Locum Tenens" Physical Therapist – Does the Change Provide Sufficient Relief?

CMS recently published guidance to implement Section 16006 of the 21st Century Cures Act, effective June 13, 2017, which allows physical therapists providing services to Medicare beneficiaries to utilize "locum tenens"...more

Avoiding Rejected Applications – Correct Form Version?

For providers and suppliers that utilize the Medicare enrollment application forms, in lieu of Internet PECOS, it is important to confirm the current version of each form prior to its completion and submission. This can be...more

2/1/2017  /  Applications , CMS , Enrollment , Medicare

CMS's Payment Suspensions Wreak Havoc: Understanding the Risks

CMS payment suspensions can cripple any provider's or supplier's operations. Yet, CMS has the authority to impose a payment suspension upon the mere existence of "reliable information" that an overpayment or fraud may exist....more

Therapy Evaluation Codes Expanded Under CMS' Proposed Rule

The most significant change for physical and occupational therapists in the Medicare proposed Physician Fee Schedule for 2017 is the replacement of current CPT codes for evaluations and reevaluations. The change reflects the...more

Proposed Enrollment Rule Changes - de Facto Exclusion?

Proposed rules, touted as enhancing the provider enrollment process, would provide CMS with sanction authority that closely parallels the OIG’s exclusion authority. Under the proposed rules, CMS would have expanded bases to...more

Outpatient Therapy Providers - Location Matters

Included in its publication announcing changes for outpatient therapy services in the 2016 Medicare Physician Fee Schedule (MPFS), CMS announced a new requirement for Medicare-certified outpatient therapy providers (e.g.,...more

Portable X-Ray Suppliers Receive Clearer Transportation Billing Guidance

Included among the 2016 Medicare Physician Fee Schedule (MPFS) changes is clarification from CMS regarding how it expects transportation charges billed by portable x-ray suppliers to be prorated among the patients receiving...more

DMEPOS Prior Authorization Rules Expand

On December 30, 2015, CMS published a final rule entitled: "Medicare Program; Prior Authorization Process for Certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies," implementing Section 1834(a)(15) of the...more

Only One Short Bite of the Apple: Change in the Medicare Enrollment Appeals Process

In keeping with the trend to strengthen its authority to deny an enrollment or revoke Medicare billing privileges, CMS has modified the appeals process in a manner that will significantly shorten the time allotted to mount an...more

Value-Based Payments Transition to Post-Acute Care: The FY 2016 Skilled Nursing PPS Rule

CMS published the final FY2016 Skilled Nursing Facility Prospective Payment System rule on August 4, 2015. In addition to updating the overall payment rate, the new rule implements key features of the Protecting Access to...more

OHCQ Mandates Submission of Policies on Resident Access to Medical Records

Maryland nursing homes must submit their policies and procedures for resident access to and requests for medical records to the Maryland Department of Health and Mental Hygiene's Office of Health Care Quality (OHCQ) by...more

Medicare Enrollment Rules - Expanded Enforcement Finalized in Regulations

On December 5, 2014, CMS published final regulations that expand the bases for CMS to deny enrollment or revoke billing privileges of an enrolled provider or supplier. These final regulations also change the method to...more

New Clarifications Affect Physician and Hospital Medicare Part B Billing for Services Provided by Nursing and Other Staff...

CMS recently released rules changing the requirements for Medicare coverage of services furnished incident to a physician’s, NP’s, or PA’s services. Howard Sollins, Donna Senft and Susan Turner explain the effect of the...more

Fingerprinting Policy Implementation - Risk to Enrollment Status?

In March 2011, when CMS published regulations to implement the Medicare enrollment screening provisions of the Affordable Care Act, the requirement for background fingerprint screening was put on hold. In a recent Special...more

Ordering and Referring Initiative - Will Phase 2 Begin January 6th?

To complete a two-phase initiative that began in 2009, CMS again announced its intent to implement the Phase 2 claims edits, which would result in claim denials if the ordering or referring physician or nonphysician...more

11/27/2013

DMEPOS Supplier Face-to-Face Encounter Requirement Again Delayed

Implementation of the face-to-face encounter requirement prior to the sale of certain DME items was delayed yet again. This is the second delay from the originally planned July 1, 2013 effective date....more

10/3/2013  /  CMS , Delays , Suppliers

Medicare Enrollment Moratoria: Implications for Service Expansion and Certain Transactions

One of the provisions of the Affordable Care Act provided CMS with the authority to impose a temporary enrollment moratorium for a particular type of provider or supplier if determined to be necessary to combat fraud and...more

CMS Reinstates Policy for Enrollment Denials Related to Unpaid Medicare Overpayments

The saga related to CMS’ policy to deny enrollments based on a history of unpaid Medicare debts continues. We first reported on the proposed regulations and corresponding policy announcement, via Transmittal 469, expanding...more

CMS Temporarily Rescinds Implementation of Enrollment Denials Related to Unpaid Medicare Overpayments

In the June 12, 2013 Payment Matters article “Enrollment Rules Continue To Provide Expanded Bases For Enforcement,” reference was made to CMS’ publication of Transmittal 469 to the Medicare Program Integrity Manual....more

Enrollment Rules Continue to Provide Expanded Bases for Enforcement

CMS continues to expand its enforcement efforts in the enrollment area. Proposed regulations titled, “Medicare Program; Requirements for the Medicare Incentive Reward Program and Provider Enrollment”, were published on April...more

6/13/2013  /  CMS , Medicare

Phase Two Edits - Temporarily on Hold

In its April 25, 2013 Medicare FFS Provider e-News, CMS announced that due to “technical issues” it would be delaying the implementation of the Phase 2 claims edits. ...more

5/3/2013  /  CMS , Medicare , PECOS

Ordering/Referring Phase 2 Begins May 1st - Claims Will Be Denied

In an April 24, 2009 transmittal, CMS announced a two-phase claims editing expansion designed to allow verification that the physician or non-physician practitioner (NPP) listed as the ordering/referring provider on a...more

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