Donna Senft

Donna Senft

Ober|Kaler

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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

9/9/2013 - Affordable Care Act CMS Employer Mandates Fraud Fraud and Abuse Healthcare Fraud Medicare Moratorium Open Enrollment

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

9/6/2013 - CMS Denial of Benefits Enforcement Healthcare Medicare Overpayment Unpaid Accounts

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

8/13/2013 - CMS Denial of Benefits Medicare Overpayment Unpaid Accounts

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

3/30/2013 - Affordable Care Act Claims Procedures CMS Compliance Durable Medical Equipment Fraud and Abuse Medicare PECOS Physicians

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