Background Checks and Fingerprints: Additional Procedures for High Risk Providers and Suppliers

The ‘Pay and Chase’ approach historically followed by the Centers for Medicare & Medicaid Services is quickly giving way to a ‘Lockout and Secure’ strategy. Earlier this year, Peter Budetti, CMS’s deputy administrator for program integrity, noted that CMS receives 18,000 applications per month for …

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Signature Requirements for Orders May Result in Denied Payment

CMS’ Change Request 6698 for the Medicare Program Integrity Manual clarifies how Medicare claim contractors review authentication of certain orders and supporting medical documentation.  This transmittal applies to claim reviews performed by Medicare Administrative Contractors (MACs), Comprehensive Error Rate …

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CMS Issues Stricter DMEPOS Supplier Qualifications

On Friday, August 27, 2010, the Centers for Medicare & Medicaid Services (CMS) issued new regulations (75 Fed. Reg. 52629) that make qualifying for and retaining Medicare billing privileges more stringent for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) suppliers. The new …

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Time Period to Submit Medicare Claims Is Shortened to Twelve Months

The proposed Medicare Physician Fee Schedule for 2011 (PFS) includes a proposal that Medicare fee-for- services claims for services furnished on or after January 1, 2010, must be filed within one calendar year after the date of services. This proposal by CMS is aimed at implementing Section 6404 of the Affordable …

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Proposed CMS Rule Would Require Group Practices to Notify Medicare Beneficiaries of Alternative Advanced Imaging Suppliers

Section 6003 of the Patient Protection and Affordable Care Act (PPACA) amended the Stark Law in-office ancillary service exception as applied to physician practices furnishing MRI, CT, PET, and potentially other diagnostic imaging services. The Stark Law prohibits a physician from making a referral for certain …

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CMS’ Confusion Over LTCF Dialysis Continues

CMS permits home dialysis in a long-term care facility (“LTCF”)—that much is clear.  But that is about as much clarity as there is, and the newly released Final Prospective Payment System (“PPS”) rule for End Stage Renal Disease (“ESRD”) does not make things much better. In 2004, CMS issued two …

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