Building an Integrated Third Party Due Diligence System Initial Screening to Audits
A Price Worth Paying?
An Update on SEF, IDB and Swap Regulation from Chris Ferreri of ICAP
Suzanne Folsom & Christopher Burnham on Private Sector Lessons
Confirmations: Plugging Into Electronic Confirmations
Corporate Law Report: Economic Espionage Act, Top FCPA Enforcement Actions, Trademark Audits, and More
On December 11, 2013, the HHS Office of Inspector General (OIG) released a report examining provider use of certain fraud controls in certified electronic health record (EHR) technology. OIG’s survey of 864 hospitals found...more
Extrapolated audits are no fun, unless you work for a recovery audit contractor (RAC). You get a Tentative Notice of Overpayment (TNO) that says the auditor reviewed 100 dates of service (DOS), found an overpayment of...more
Earlier this month, CMS posted three new documents related to the 2-midnight rule for inpatient admissions on its webpage for inpatient hospital reviews: new FAQs, as well as CMS directions for selecting hospital claims for...more
Previously, we reported how the U.S. District Court for the District of Columbia found in UPMC Braddock v. Harris that providers of healthcare services are subject to federal equal employment opportunity mandates applicable...more
The consolidation trend in hospital and health systems continues. To address perceived inefficiencies and quality of care issues, hospitals are attempting to form larger enterprises to create scale, expand geographically,...more
The U.S. Government Accountability Office (GAO) recently published the results of a study examining the effectiveness of CMS’s contractors that conduct postpayment claims reviews to identify improper payments (i.e., Medicare...more
Following a detailed study of the manner by which the Centers for Medicare and Medicaid Services (“CMS”) engages in postpayment claims reviews to identify improper payments, the U.S. Government Accountability Office (“GAO”)...more
The American Health Care Association (“AHCA”) has reported that the Centers for Medicare & Medicaid Services (“CMS”) will be making efforts to streamline its audit structure. Among the changes will be the development of a new...more
In an effort to improve patient care, the Centers for Medicare and Medicaid Services (“CMS”) established electronic health record (“EHR”) Incentive Programs, which provide financial incentives for the “meaningful use” of...more
An identical version of the Medicare Audit Improvement Act (MAIA), reported on in the March 25, 2013 issue of Health Headlines when it was introduced in the House, has now been introduced in the Senate by Senator Roy Blunt...more
District Court Finds That Medical Group’s Failure to Further Investigate Audit Results May Violate Requirement to Return Overpayments -
Internal audits of third-party payment claims – frequently...more
Hospitals are under intense scrutiny. The federal government knows that one sure way to reduce healthcare costs is to get hospitals to lower their costs. Hospitals feel the pinch given the need to generate revenue but know...more
Acting CMS Administrator, Marilyn Tavenner, recently reaffirmed the agency’s concern that the increased use of electronic health records (“EHRs”) has contributed to increases in fraudulent billing practices by providers. At a...more
The U.S. Department of Labor (the "DOL") has recently enhanced its enforcement activities with respect to group health plans by significantly increasing the number of audits it is conducting. In addition, the DOL's audit...more
The government has been increasing its focus on healthcare fraud involving “quality” of care. This is an extremely difficult issue, especially for prosecutors. It is very difficult to define “quality” standards and then...more
Healthcare suppliers and service providers live in a regulated world. They are constantly under audit scrutiny. Sometimes federal agencies (i.e private contractors) conduct the audits; other times state agencies conduct the...more
Originally published in Compliance Today on December 1, 2012.
..Covered entities are now subject to privacy and security audits by OCR.
..OCR published audit protocols regarding its standards for such...more
The march towards electronic health records (“EHRs”) and health information exchange continues. It is worth noting a number of recent changes to the Medicare and Medicaid Meaningful Use programs governing incentives for...more
One of the less well-known provisions of the Health Information Technology for Economic and Clinical Health (or "HITECH") Act is the requirement that the U.S. Department of Health and Human Services ("HHS") periodically...more
As part of health care reform, the federal government mandated that a pilot HIPAA audit program (the “HIPAA Audit Program”) be developed to ensure compliance with HIPAA’s privacy and security rules and its breach notification...more
On June 26, 2012, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) released on its website the protocol that it has developed to serve as a guideline for recently-implemented HIPAA...more
Protocol provides clues regarding areas of focus for ongoing HIPAA audits assessing compliance with the Privacy, Security, and Breach Notification Rules.
The Office for Civil Rights (OCR) at the Department of Health...more
In this issue:
- A Sign of the Times: Nonpayment of Resident Accounts, Transfer/Discharge and Related Issues
- Responding to an Audit? Be Prepared!
- Ken’s Quote of the Month
An excerpt from...more