Donna Senft

Donna Senft


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Latest Publications


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

9/17/2015 - ALJ Appeals CMS Enrollment Medicare Medicare Claims Appeals Process PECOS

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

9/4/2015 - CMS IMPACT Act Inpatient Quality Reporting Medicare PAMA Patient Prospective Payment System Skilled Nursing Facility Value-Based Payments

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

1/15/2015 - Department of Health Nursing Homes Policies and Procedures Reporting Requirements

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

1/12/2015 - Ambulance Providers CMS Enrollment Final Rules Healthcare Medicare

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

7/31/2014 - CMS Healthcare Medicare Medicare Part B New Regulations Nurses Physician Assistant Physicians

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

5/7/2014 - Affordable Care Act Background Checks CMS Fingerprints Healthcare MACs Medicaid Medicare

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


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 Claim Procedures CMS Compliance Durable Medical Equipment Fraud and Abuse Medicare PECOS Physicians

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