News & Analysis as of

Overpayment Audits

King & Spalding

OIG Audit Finds Medicare Overpaid Hospitals an Estimated $79 Million for Enrollees Who Had Received Mechanical Ventilation

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On August 12, 2024, OIG announced the results of an audit of payments made to hospitals for inpatient claims with the Medicare Severity Diagnosis-Related Groups (MS-DRGs) that require ninety-six hours of consecutive...more

Polsinelli

Provider Reimbursement Disputes Go Back to 1984 Following Supreme Court’s Regulatory Reset

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One could forgive the healthcare industry for thinking someone drove Doc Brown’s DeLorean time machine through One First Street when it awoke on Friday, June 28, to a blast from the past....more

Health Care Compliance Association (HCCA)

OIG: COVID-19 UIP Overpaid Providers $784M; HRSA Will Recoup Money

Hospitals and other providers should brace for recoupment of possibly hundreds of millions of dollars they were reportedly overpaid for services provided under the COVID-19 uninsured program (UIP) in the wake of new audit...more

Health Care Compliance Association (HCCA)

[Event] 2023 Board & Audit Committee Compliance Conference - October 23rd - 24th, Fort Lauderdale, FL

Discover today's best practices for your role in healthcare compliance oversight - The Office of Inspector General of Health and Human Services expects healthcare board members, board audit/compliance committee members,...more

Proskauer - Employee Benefits & Executive...

SECURE 2.0 Delivers New Rules for Correcting Retirement Plan Errors

As part of our ongoing series on SECURE 2.0, this post discusses three significant changes to corrections of common retirement plan errors: (1) New rules for correcting overpayments, (2) expansion of the Self-Correction...more

Nelson Mullins Riley & Scarborough LLP

Understanding the Medicare Overpayment Appeals Process

Every Medicare provider should understand the Medicare administrative appeals process. Providers are entitled to be reimbursed for their services and want to keep those reimbursements safe from audits. However, if Medicare...more

Oberheiden P.C.

10 Keys to a Successful Pharmacy Audit Appeal

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Medicare, Medicaid, and pharmacy benefit manager (PBM) audits can result in substantial losses for pharmacies. If auditors uncover evidence—or apparent evidence—of overpayments, not only can they initiate recoupments, but...more

Fox Rothschild LLP

My Medical Practice Is Being Audited. Now What?

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Private and government payers are initiating more medical practice audits, and that trend is likely to continue. In order to successfully navigate the process, providers should prepare in advance to meet the audit challenge. ...more

Lippes Mathias LLP

OMIG to Adopt New Fraud, Waste and Abuse Prevention Requirements

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In the July 13, 2022 issue of the New York State Register, the New York State Office of Medicaid Inspector General (OMIG) published a proposed regulation that it will likely adopt this fall. The proposed regulation will add...more

McDermott Will & Emery

Need a Do-Over? IRS Expands and Updates Qualified Plans Correction Guidance

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The Internal Revenue Service (IRS) issued Revenue Procedure 2021-30, which provides an updated version of the Employee Plans Compliance Resolution System (EPCRS). EPCRS is the IRS’s comprehensive program for plan sponsors to...more

Foley & Lardner LLP

Some Welcome News: IRS Expands and Modifies Its Correction Methodology with New Employee Plans Compliance Resolution System...

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Plan sponsors and other administrators of eligible retirement plans must ensure that these plans are operated properly in accordance with the applicable requirements of the Internal Revenue Code, including the applicable plan...more

Morgan Lewis

IRS Expands Self-Correction Procedures, but Eliminates Anonymous Voluntary Correction Program

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The Internal Revenue Service (IRS) made important changes to the Employee Plans Compliance Resolution System (EPCRS) in Revenue Procedure 2021-30 that are helpful for plan sponsors as they expand the ability of plan sponsors...more

Holland & Hart - The Benefits Dial

E-P-C-R-S, find out what it means to me … new IRS Correction Guidance

On July 16, 2021, the IRS released updated Employee Plans Compliance Resolution System (EPCRS) guidance for Plan corrections in the form of Rev. Proc. 2021-30. The changes affect the three programs offered by the IRS for...more

Oberheiden P.C.

ZPIC Audits: What Healthcare Providers Need to Know

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Zone Program Integrity Contractors (ZPICs) are federal contractors that work under the direction of the Centers for Medicare and Medicaid Services (CMS) to uncover fraudulent billings under Medicare. ZPICs have broad...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 30, Number 17. News Briefs: May 2021

Report on Medicare Compliance 30, no. 17 (May 3, 2021) - In a new provider compliance audit, the HHS Office of Inspector General (OIG) said Visiting Nurse Association of Maryland (VNA) received overpayments of $2.1...more

King & Spalding

HHS Releases New Frequently Asked Questions Regarding CARES Act Provider Relief Funds - April 2021

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Last week, HHS released eleven modified Frequently Asked Questions (FAQs) regarding payments distributed to providers via the CARES Act Provider Relief Fund. The FAQs cover audits and overpayments, sharing funds with...more

Maynard Nexsen

How to Avoid Healthcare Overpayments: Top Five Mistakes Providers Make and the Real Cost of Non-Compliance

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Over the last 25 years, I have assisted healthcare providers as a lawyer and as a compliance professional with handling routine overpayment matters, internal and external billing investigations, and fraud and abuse matters. ...more

Husch Blackwell LLP

Hospice Audit Series: The Latest Developments and Strategies for Success in the Ever-changing Audit Landscape

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Hospice Audits Series Audits are a fact of life for hospices—it’s not a matter of “if” a hospice will be audited, but “when.” The alphabet soup of audits has expanded, from UPICs to SMRCs, CPIs, TPEs and more. With the...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 29, Number 43. News Briefs: December 2020

Report on Medicare Compliance 29, no. 43 (December 7, 2020) - In a new provider compliance audit, the HHS Office of Inspector General (OIG) said The Palace at Home, a for-profit home health care agency (HHA) in Miami,...more

King & Spalding

OIG Announces Resumption of Medicare Inpatient Short Stay Audits

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In its November 2020 Work Plan update, OIG announced it will begin auditing short stay inpatient hospital claims under the Two Midnight Rule, and when appropriate, recommend overpayment collections. OIG does not specify the...more

Health Care Compliance Association (HCCA)

In Provider Compliance Audit, OIG Said HHA Was Overpaid $5.9M

Report on Medicare Compliance 29, no. 30 (August 24, 2020) - Mission Home Health of San Diego Inc. was overpaid $61,718 in 2015 and 2016, which was extrapolated to $5.9 million, according to the latest Medicare home health...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 29, Number 22. News Briefs: June 2020

Report on Medicare Compliance Volume 29, no. 22 (June 15, 2020): - The HHS Office of Inspector General has updated its Work Plan, and new items include opioid treatment challenges during the COVID-19 pandemic. - In a...more

King & Spalding

General Counsels Decision Tree for Healthcare Related Internal Investigations

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Healthcare systems, hospital networks, and other healthcare providers regularly face challenges that may require an internal investigation to determine the root cause of an issue in order to evaluate how best to remediate and...more

King & Spalding

OIG Hospital Compliance Program Audit Claims $22 Million in Extrapolated Overpayments

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A recent report issued by OIG finding an Indiana community hospital owed over $22 million in extrapolated overpayments carries some important lessons for hospitals audited under OIG’s hospital compliance program. As described...more

Baker Donelson

New Medicaid DSH Audit Guidance: Its Impact on Pending and Recent State DSH Audits

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On December 31, 2018, the Center for Medicaid and CHIP Services issued a notice indicating that CMS was altering its prior audit guidance for Medicaid Disproportionate Share Hospital (DSH) audits that had previously been...more

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