Webinar on What is a Compliance Program 101!


Medical Auditing Solutions is providing a webinar in conjunction with The Cornerstone Insurance Group (Cornerstone) to discuss the Basic Compliance Program Requirements.  We will learn what a compliance program is, what laws require it, the elements of a compliance program, and how the program can be beneficial to the healthcare provide.

Any and all healthcare providers (medical and dental practices as well as ancillary providers such as DME, Home Health, Hospice, etc.) taking Medicare and Medicaid should attend.

No CEU credit is formally given, but you will be welcome to send the handout received post attendance to your accrediting agency and ask for credit.  Some will provide and the worse they can do is say no.

The Cornerstone Insurance Group (Cornerstone) in no way endorses the accuracy of the information being provided.  In registering for this program, you will release and hold Cornerstone harmless of any and all actions you take as a result of this call.  This call is basic information and is simply an avenue for you to educate yourself on compliance program requirements.  This call in no way provides legal advice or provider specific advice without adequate documentation to review.  This is informational purposes only.

Cornerstone providers Total HR management & products including benefits management, Total Insurance products, Wellness Management Services.  Read more about the services Cornerstone offers you may find services that could benefit your organization.  They are primarily in Missouri and surrounding states but do cover additional states.

Program Title:  Compliance Program Basics and Elements

Date:                     July 24, 2012

Time:                    11:30 am-12:30 am CST

Cost:                      Complimentary

Register:              https://cc.readytalk.com/r/yhypbz3hj2p

About more about the speaker and Medical Auditing Solutions LLC:

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller is Certified in Healthcare Compliance.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

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Is Your Credit Card Terminal PCI HIPAA Compliant?


World Pay is a company that I have come across that has some really good educational information for clients and perspective clients on Payment Care Industry or PCI Compliance.  HIPAA extends to protect the financial information of clients.  It is important that you have policies regarding your PCI practices or accepting and processing credit card payments.  If your credit card processing company helping you?  Is your credit card terminal PCI Compliant, feel free to check the lists for WPVeriFone EOL Products and WPHypercom T7Plus End of Life that have reached”End of Life” or are no longer compliant.

A company can be out of PCI compliance in two ways 1) the terminal they use does not meet criteria and 2) through processes of gathering, transmitting and storing data.

Let me tell you what impressed me about World Pay.  They have a terminal that is end to end encrypted to protect financial data.  This company has a tremendous about of education materials on this topic. There fee of $14.99/month of PCI compliance includes 24/7 customer service, guidance to get your policies and procedures in place, a third party vendor to provide PCI Accreditation and Certification for that process only, and $30K of indemnity coverage when using their standard terminal or $100K indemnity coverage if your are using their end to end encrypted terminal, they help with negotiations with visa, master card, etc., if their is a breach.  Additional medical audit and HIPAA breach defense coverage may be obtained through Jim Patterson at Agape Insurance

It is important that you ensure your credit card processing machine and process is HIPAA compliant.  Educate yourself and make an informed decision.  I have included links to PCI websites for further explanation of PCI Compliance.

What will you need to have a free PCI Compliance review provided?

1.  Your Credit Card Statement; Does your statement say “non-validation of PCI” with a fee?

2.  Name/Model# of the Terminal(s) being used

3.  Do you have policies and procedures for use, storage and transmission?

4.  Mention this blog from Medical Auditing Solutions

How do you get this complimentary PCI Compliance Review?

Have the information above available and Contact Martin Anderson with World Pay at *martin.anderson@worldpay.us*

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Texas Dental Providers – Take Aways from HHSC Committee Meeting 3/20/12


I listened to the live Texas Senate Committee meeting regarding the Health and Human Services Commission (HHSC) Charge 4 (dental & orthodontics) yesterday 3/20/12.  Unfortunately, this Senate Committee is concerned about the amount of money paid for orthodontic services and convinced Orthodontic services were provided at an abusive level and they want this money back.  I am providing what I took away from this meeting and we will discuss how to protect yourself.

  1. Senator Jane Nelson is willing to push thru legislation to allow parents in the treatment room.  I didn’t understand this…I suspect she has received a complaint from a parent where the Dental Provider refused to allow the parent in the treatment room.  My opinion is, this is one thing if the room has a door or if the patient is sedated because you do not want to add liability to your business.  Having a second company staff member in the room present will reduce risk as well.  As for HIPAA, what are your privacy and security policies for this situation?  If you do not have policies, they have been required since 2003 and 2009 respectively so very important to get this done.
  2. They want to go after dentist for the unlimited orthodontic visits.  Policy said “unlimited”!  Keep in mind if the Dental Provider was racking up unnecessary visits, it doesn’t matter if it is unlimited visits in policy, the visits were unnecessary therefore a potential fraud and abuse overpayment.  If these were legitimate visits and necessary, you should not pay that money back.  So policy for this is being reduced to 12 visits, they say.
  3. They pay for transportation to the dentist if the patient cannot afford it.  At present the patients are paid upfront or MCD pays the transportation company.  In the future, they will have to provide proof of visit and proof they used the transportation to be reimbursed.
  4. They are looking at bundling orthodontic rates versus per visit rate.
  5. More talk of suspending provider numbers based on allegations of credible fraud.  This is huge and critically important to include exit interviews with staff that is leaving the company.  You also need to have a compliance program with reporting mechanism in place.  If you collect $5M or more in Medicaid funds you were required to have a healthcare compliance program in 2007.  All other Medicaid providers are required to have a compliance program by 2013.
  6. Inspector General has 31 current investigations of Orthodontic practices at this time.
  7. Senator Jane Nelson and the committee want the business to have to be licensed and registered with the dental board similar to a pharmacy with the pharmacy board.  I suspect changes will follow for a proposal of such.  This will bring additional revenue into the Dental Board but it will permit investigations into complaints of ABC Dental versus the need for a dental providers name which is the current requirement.
  8. Expect audits to pick up on Orthodontic services.  They noticed as of 10/1/11 when the requirement to send molds went into place, request dropped and PARs were denied.  If you provided orthodontics to children under 13 or now 12, those are especially at risk for audit.
  9. They put a lot of emphasis on HLD Scores.  Where do you record these and how you measure to get the score?
  10. The TMHP Medicaid contractor responsible for reviewing this information basically rubber stamped requests.  They did not review for “medical necessity;”  it was primarily to make sure the form was completed and the HLD Score was >=26.  The Dental Director was terminated and they have hired a replacement.  They HHS/IG will be auditing the approved PARs (Prior Auth Requests) and recouping money.  The debate is if they will recoup from TMHP or from the provider.  Again, if the services were fraudulent and dishonest it, I fully expect they will go after the provider.  There is always a possibility if TMHP didn’t review and it did not meet the coverage criteria, they will try to recoup from the provider as well.  They expect these audits to be complete in 6-12 months and they have already started.
  11. By using Dental Managed Care Payers, these organizations have experience in other states and they have ideas on how to reduce Fraud & Abuse (F&A).  They think by using someone with experience to review and process these claims will reduce F&A.
  12. On the federal level, in 2010 Office of Audit Services contacted Texas inquiring about Orthodontic billing and providers.  So the federal government has taken notice of Texas and since they provide funding to the medicaid program, Texas has to respond to the concerns.
  13. No recruiting clients in parking lots….…this seems to be an issue.
  14. The HHSC office admitted the policies were such that it didn’t catch issues and the department processing was not staffed properly.
  15. I would expect a tremendous increase in audits and policy changes.
  16. Texas spent as much as 49 other states total from 9/1/08-5/28/11 on Orthodontic services.  An additional 500,000 kids were seen for checkups after the rates increased in 2008 by 50-100% than in previous years.
  17. The committee suggested HHSC do a Cost Benefit Analysis on providing orthodontic care to children and if that prevented excessive spending later if it were not done.

Now, what should you do?  I strongly recommend the following and sometimes it is good to get an outside consultant to review because of objectivity and the familiarity with issues being identified.

  1. Make sure you have HIPAA policies in place that are applicable to your business.
  2. Assess whether you need a healthcare compliance program now (because you were required in 2007) or if not make a plan to get this done.
  3. Items 1 and 2, a vital if you are investigated now even if not required.  Corporate culture is first questions the government asks.
  4. A sample audit of claims.  This is critical because you need to assess your risk as a company.  Assess the documentation versus coverage criteria.
  5. If audited, NEVER just cut a check for the overpayment requested!  Why, you ask?  The payer sees this as admission of guilt and if they haven’t extrapolated already they are more likely to do so.  This is not a good surprise to get in the mail6-12-14 months later!!  I have seen this happen.  Get a consultant and attorney and prepare a defense.  It will be less expensive to do when you get the audit than after the appeal process has started.

We work with several dental practices and the goal is to educate providers so they reduce risk and pass audits.  We also work with Looper, Reed, and McGraw LP, a law firm with attorneys that specializes in dental practices.  We work as a team with our practice and emphasize “proactive”operations.  We will be happy to schedule

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Training for Compliance & HIPAA Privacy and Security


Medical Auditing Solutions LLC launched the Compliance University in September 2011 and is please to announce that for 6 of the programs we have received Continuing Education Credits by Texas Occupational Therapist Association (TOTA) (15 hours) , Texas Board of Professional Counselors (6 hours minimum) , and BOC USA (9.5 hours).

What are you waiting for?  You have to train staff annually on compliance program requirements, fraud and abuse, billing,privacy and security. You have to be able to prove this training was given.  Does your staff have time to develop, track and update?  Did you know the OIG is auditing for these policies, training, sanction checks, and more in 2013 for providers that $5M in annual collections from Medicaid programs?  Did you know that OCR is auditing all types and sizes of healthcare providers from HIPAA privacy and security in 2012 and years to come?  Did you know the state inspector generals and health and human services will be auditing for these policies as well?  We can help you will all aspects of your compliance and HIPAA programs.

These requirements apply to all healthcare providers, DME, home health, physicians, and dental providers.  The size of your business does not matter for HIPAA.  As of  February 2013 for Compliance applies to all as well.

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

PRESS RELEASE: KYMESA Announces Partnership with Medical Auditing Solutions LLC


Medical Auditing Solutions LLC (“MAS”) is excited to announce its partnership with Kentucky Medical Equipment Suppliers Association (“KYMESA”).   KYMESA has selected MAS to be their preferred vendor for Healthcare Compliance, HIPAA,  and Billing Analysis Programs.

Angela Miller is the founding owner of MAS a company specializing in Healthcare compliance & HIPAA privacy program development and training, billing analysis, and cash flow management.  Ms. Miller spent 12 years in HME starting here in Kentucky where she grew up and her family continues to reside.  She prior experience  as a compliance officer where she managed a very proactive successful program for 5 years.

MAS just released MAS Compliance University which has 4 e-learning programs currently with 3 more to be uploaded for compliance and HIPAA privacy training.  These programs have a pretest, required one hour program, required test and evaluation all of which are tracked and can be exported to excel for client records.  MAS also provides billing compliance audits which not only keeps you in compliance with the coverage criteria but will help improve the overall efficiency of the business processes as she understands the importance of running lean with the reimbursement cuts and competitive bidding on the table.

Don’t forget a formal compliance program is required to be in place by 2013.  If you are not doing annual HIPAA privacy training and don’t have security policies, this is required.

You may contact Kentucky Medical Equipment Suppliers Association about their membership benefits and how they work on the state and federal level:

#394, 1303 US 127 S

Suite 402

Frankfort, KY 40601
Cell (407) 435-2667
Fax (502) 416-0328

Teresa Camfield, Director

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

PRESS RELEASE: Compliance University Rollout


September 9, 2011

Medical Auditing Solutions LLC is excited to announce the release of our new service called “Compliance University.”  The Compliance University focuses on the healthcare regulatory compliance annual training requirements for all employees.  HIPAA requires annual privacy and security training for all employees (2003 & 2010) respectively.  Compliance (billing, contracts, and relationships) is required as part of the Healthcare Reform Act and the Patient Protection Accountability and Affordable Care Act due 2013.  This training is only one aspect of an effect Compliance program.  Privacy and Security is primarily monitored, audited and investigated by HHS and Office of Civil Rights.  Compliance is primarily monitored, audited, and investigated by CMS, OIG, HHS, FBI.  The monitoring, auditing, and investigation may start in other federal and state government areas.

All programs are general in nature and meant for any type of health care providers.  They are between 40 minutes and 1 hour.  Each program is followed by a test of comprehension, an evaluation that is required to receive the completion certificate.  The Compliance University will provide the company with status, completion, grade reports.  We have additional programs to be released within the next few weeks as well to complete the set.  The programs contain examples and explanation for various health care industries so the knowledge obtained can be applied in any setting.

We look forward to helping you with your compliance program training as well as other areas of development and tracking that you may need to complete.  Check out our website at www.MedicalAuditingSolutions.com and Compliance University.  Mention this press release “PRESS” and receive 10% discount.

FBI-Federal Bureau of Investigation

HHS-Health and Human Services

OCR-Office of Civil Rights

OIG-Office of Inspector General

Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.

Speaking Engagements 2011


March 1, 2011
California Association of Medical Providers & Suppliers

Angela Miller speaking for Zirmed Financial Workout Webinar Series

April 20, 2011

VGM’s Heartland Conference

June 8 – 9, 2011

Texas Osteopathic Medical Association

June 17, 2011  10am-noon

Medtrade Fall 2011

October 26 & 27

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KY Medical Equipment Suppliers Associate (KYMESA)

November 9, 2011 – Compliance Program Implementation

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PaychexsIrving Texas office contact Christina Rossini to register.

December 6, 2011 – Compliance Program Requirements

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Medtrade Spring 2012

April 10-12, 2012

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American Association of Osteopathic Executives

May 20-22, 2012

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Angela Miller of Medical Auditing Solutions LLC has been in health care compliance, auditing, billing, collections and HIPAA for over 18 years.  Ms. Miller has made it the  focus of the business to help providers run their businesses efficiently, collect money, and maintain compliance with federal and state regulations and coverage criteria through compliance program development, management and training.  Ms. Miller is very experienced with Medicare & Payer audits.  Ms. Miller ran a very successful compliance program for over 5 years for the largest private held HME/Pharmacy provider in the US at the time.  Ms. Miller  also works as a contract compliance officer to provide an avenue to compliance training to staff, implementation of policies, as well as handling anything that affects cash flow from the initial intake to back-end collections. You can visit our website at Medical Auditing Solutions LLC.