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Bass, Berry & Sims PLC

CMS Solicits Comments to Clarify Parameters on MAC Downcoding of Complex Drug Administration Infusion Services

In the proposed CY 2025 Physician Fee Schedule (PFS) published in the Federal Register on July 31, the Centers for Medicare & Medicaid Services (CMS) is soliciting comments on a proposal to revise the Medicare Claims...more

McDermott+

No Congressional Doc Fix on the Immediate Horizon: What Happens Next?

McDermott+ on

Congress is on its way to extending the stop-gap funding bills into March (and may have already done so by the time you read this). Absent from the legislation to continue funding the federal government is a “doc fix” that...more

McDermott+

Remote Monitoring Services Under Review: Update on Potential Medicare Coverage Policies (May 2023 Update)

McDermott+ on

On May 19, 2023, Novitas Solutions and First Coast Options sent an email to certain interested parties, with whom they had engaged following the multijurisdictional contractor advisory committee (CAC) meeting explaining that...more

Health Care Compliance Association (HCCA)

MA Final Rule: CMS Requires Two-Midnight Rule, Puts Limits on Internal Coverage Criteria

In what passes for neon lights in the regulatory world, CMS said Medicare Advantage (MA) plans must follow the two-midnight rule, its case-by-case exception and the inpatient-only (IPO) list, according to the final 2024 rule...more

Bass, Berry & Sims PLC

CMS Audits: Part 1 The ABCs of Medicare and Medicaid Claims Audits: Understanding the Audit Contractors

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Because Medicare and Medicaid claims audit requests can look like routine billing-related correspondence, they can be easy to miss, leading to expensive and potentially catastrophic consequences. Providers, therefore, should...more

King & Spalding

GAO Releases Report and Recommendations to CMS to Address Risks Posed by Provider Enrollment Waivers and Flexibilities Implemented...

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On December 19, 2022, the U.S. Government Accountability Office (GAO) released a report titled, “Medicare: CMS Needs to Address Risks Posed by Provider Enrollment Waivers and Flexibilities” (GAO-23-105494). The report...more

Nelson Mullins Riley & Scarborough LLP

More on Understanding the Medicare Overpayment Appeals Process

The initial article on this subject discussed generally why Medicare providers need to understand the Medicare administrative appeals process, especially in connection with overpayment determinations, Additional Documentation...more

Verrill

2021 Medicare Cost Report Preparation, Reminders and New Developments for Hospitals

Verrill on

With many hospitals well into their FY 2021 Medicare cost report preparation, here is a brief reminder of the process required for protesting items, as well as a summary of two new developments for Medicare Graduate Medical...more

Baker Donelson

CMS Budget Justification Requests Increased Audit and Appeals Funding

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The Centers for Medicare & Medicaid Services' (CMS) FY 2022 Budget Justification request to Congress suggests an increased focus on Medicare claim reviews and an effort to decrease the number of claim denials overturned...more

Oberheiden P.C.

5 Defense Strategies for MAC/RAC Audits

Oberheiden P.C. on

Medicare pays billions of dollars in fraudulently billed claims each year despite the various tools the Medicare system has at its disposal. Because of this problem, the Centers for Medicare and Medicaid Services (“CMS”)...more

Sheppard Mullin Richter & Hampton LLP

CMS Announces New Geographic Direct Contracting Model: Letters of Interest Due by December 21, 2020

On December 3, 2020, Centers for Medicare & Medicaid Services (“CMS”) announced key details concerning a new value-based reimbursement and patient care model – the Geographic Direct Contracting Model (the “Model” or “Geo”)....more

Bricker Graydon LLP

Medicare program resuming fee-for-service audits and DMEPOS prior authorization program paused during COVID-19 pandemic

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Despite many parts of the country seeing upticks in COVID-19 cases and hospitalizations, the Centers for Medicare & Medicaid Services (CMS) is ready to get back to some of its normal oversight activities related to the...more

Bricker Graydon LLP

Medicare to require prior authorization for certain outpatient department services starting July 1, 2020

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In the Calendar Year 2020 Outpatient Prospective Payment System/Ambulatory Surgical Center Final Rule (2020 OPPS Final Rule), the Centers for Medicare and Medicaid Services (CMS) established a prior authorization process and...more

McDermott Will & Emery

CMS Provides Flexibility for Independent Freestanding Emergency Departments to Enroll in Medicare as Hospitals During the COVID-19...

McDermott Will & Emery on

On April 21, 2020, the Centers for Medicare & Medicaid Services (CMS) issued Quality, Safety & Oversight memorandum QSO-20-27-Hospital (QSO Memo), addressed to state survey agencies to provide guidance to independent...more

Nossaman LLP

CMS Expands the Accelerated and Advance Payment Program in Response to COVID-19

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On March 28, 2020, the Centers for Medicare & Medicaid Services (“CMS”) announced that the agency would provide relief to Medicare providers and suppliers by expanding the Accelerated and Advance Payment Program for the...more

McGuireWoods LLP

Payment Advances For Medicare Providers, Suppliers May Ease Liquidity Issues – Six Key Points

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On March 28, 2020, the Centers for Medicare & Medicaid Services (CMS) released guidance expanding its Accelerated and Advanced Payment Program, which now allows most Medicare Part A and Part B providers and suppliers to...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 29, Number 7. News Briefs: February 2020 #4

Report on Medicare Compliance 29, no. 7 (February 24, 2020) -  Guardian Elder Care Holdings Inc., which operates more than 50 skilled nursing facilities (SNFs) in Pennsylvania, Ohio and West Virginia, and its related...more

Health Care Compliance Association (HCCA)

Observation Is Attracting Audit Attention; Hours Are a Risk, And Watch Out for the MOON

Report on Medicare Compliance 29, no. 5 (February 10, 2020) -  At least two Medicare administrative contractors (MACs) have set their sights on observation services, and there may be more to come. WPS is auditing...more

Bricker Graydon LLP

Reminder to providers: CMS modified supporting documentation requirements for cost-reporting periods beginning on or after October...

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On August 17, 2018, the Centers for Medicare and Medicaid Services (CMS) issued the FY 2019 Medicare IPPS final rule. Part of the rule modified the supporting documentation required under 42 CFR 413.20 to be submitted with...more

Polsinelli

CY 2020 OPPS Proposed Rule – HHS Seeks Comments on 340B Payment Reductions and Remedies

Polsinelli on

This past week, CMS confirmed it will continue the 2018 and 2019 underpayment policy for certain 340B covered entities unless the D.C. Court of Appeals upholds the lower court’s ruling that it is unlawful. In that case, CMS...more

Arnall Golden Gregory LLP

CMS Releases MLN Matters Related to Appeals of Claims Decisions

On April 12, 2019, CMS released a Medicare Learning Network Matters article (MLN) in connection with Change Request (CR) 11042, which revises the Medicare Claims Processing Manual (Publication 100-04, Chapter 29 – Appeals of...more

King & Spalding

CMS Updates Manual and Releases MLN Matters Article Regarding Appeals of Claims Decisions

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CMS recently issued a Medicare Learning Network (MLN) Matters article in connection with Change Request 11042 released on April 12, 2019 (the Change Request), which revises the Medicare Claims Processing Manual (Publication...more

King & Spalding

CMS to Begin Enforcing “Longstanding” Accounting Classification Rule for Crossover Bad Debts

King & Spalding on

Last week, CMS announced on its website that for cost reporting periods beginning on or after October 1, 2019, providers must comply with a so-called “longstanding” rule to claim reimbursement for crossover bad debts from the...more

Baker Donelson

Medicare Target, Probe and Education Audits Require Immediate and Full Attention from Providers/Suppliers

Baker Donelson on

While many Medicare providers and suppliers may not yet have experienced a Targeted Probe and Education (TPE) audit, they should be on the lookout for this newest weapon in the medical review arsenal. It is important that...more

King & Spalding

Legislative Update: U.S. House of Representatives Passes Four Medicare Bills

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On September 12, 2018, the U.S. House of Representatives approved by voice vote four bipartisan bills to amend various provisions of the Medicare program. A summary of each bill is below....more

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