Paul Kim

Paul Kim

Ober|Kaler

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CMS Instructs MACs to Participate in ALJ Hearings

CMS officially added a new Section 3.9 to the Medicare Program Integrity Manual, effective October 27, 2014. These provisions instruct Medicare Administrative Contractors (MACs) to assign a physician to participate at...more

11/14/2014 - Administrative Hearings ALJ Appeals CMS MACs

Audits and Appeals: A Routine Cost of Doing Business with Medicare

The Centers for Medicare and Medicaid Services has unleashed an alphabet of auditors to identify overpayments. These auditors are armed with the authority to conduct pre-payment reviews, and post-payment audits, as well as...more

10/2/2014 - Auditors CMS Medicare Medicare Appeals Council Webinar

WEBINAR: Breach, Enforcement and Beyond: HIPAA Breach Notification Analysis and OCR Enforcement Activities

The Office for Civil Rights of the US Department of Health and Human Services revised the breach notification regulations last year in order to make the analysis of whether a breach occurred more objective. In addition, OCR...more

9/18/2014 - Breach Notification Rule Data Breach Data Protection Enforcement Enforcement Actions HHS HIPAA OCR

HIPAA Security Risk Analyses

As noted in Paul Kim and Hannah Whitman Clark's article regarding HIPAA Security Risk Analyses, CEs and BAs are required to review and update their risk assessments only under certain conditions after completing their initial...more

4/1/2014 - Data Protection HIPAA PHI Risk Assessment

Security Rule Compliance: The Importance of Performing Regular Risk Analyses

It is likely that you are familiar with the HIPAA Security Rule’s mandate that covered entities and business associates document the decision making process that led to the selection of their means to achieve security for...more

4/1/2014 - Data Breach Data Protection ERISA PHI Risk Assessment

A Calm Before the Storm: Updates on CMS Audit Activity

In February 2014, CMS made two announcements that affect future Medicare audits. First, CMS instructed RACs to stop issuing post-payment additional documentation requests (ADRs) after February 21 and instructed MACs to stop...more

3/7/2014 - Audits CMS Document Requests Healthcare MACs Medicare RACs

RAC Relief (Sort Of)

CMS announced that it would reduce the number of additional documentation requests (ADRs) available to its Recovery Audit Contractors (RACs). ...more

5/21/2013 - CMS Recovery Audit Contractor Required Documentation

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