Senate Finance Committee Seeks Feedback on Fighting Fraud & Abuse as They Look at ZPICs


Reposted from email blast received May 2, 2012.
FOR IMMEDIATE RELEASE
May 2, 2012
CONTACT:  Julia Lawless/Antonia Ferrier (Hatch)              (202) 224-4515
                            Communications Office (Baucus)                          (202) 224-4515 

HATCH, BAUCUS LEAD FINANCE COMMITTEE MEMBERS IN BIPARTISAN EFFORT TO COMBAT WASTE, FRAUD, & ABUSE IN
MEDICARE & MEDICAID PROGRAMS
In an open letter to members of the health care community Senators write, “Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.”


WASHINGTON – Today, six members of the Senate Finance Committee, led by Ranking Member Orrin Hatch (R-Utah) and Chairman Max Baucus (D-Mont.), announced a bipartisan effort to begin soliciting ideas from interested stakeholders in the health care community regarding effective solutions to improve federal efforts to combat waste, fraud, and abuse in the Medicare and Medicaid programs. Joining Hatch and Baucus in the effort are:  Senators Tom Coburn (R-Okla.), Ron Wyden (D-Ore.), Chuck Grassley (R-Iowa), and Tom Carper (D-Del.).

In an open letter to members of the health care community, the Senators wrote, “We believe federal efforts would be strengthened by input from members across the health care community – providers, payers, health plans, contractors, non-profit entities, consumers, data analytics entities, governmental partners, and patients. Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.”

This week, the lawmakers invited interested stakeholders to submit white papers offering recommendations and innovative solutions to improve program integrity efforts, strengthen payment reforms, and enhance fraud and abuse enforcement efforts. Submissions are due by June 29, 2012. A summary document highlighting key proposals will be compiled and released later this year.

The Senate Finance Committee has jurisdiction over the Medicare and Medicaid programs.

To view a signed copy of the letter click HERE.

Below is the full text of the letter:

May 2, 2012

To Members of the Health Care Community:

According to the Government Accountability Office (GAO), few programs are as much at risk for fraud, waste and abuse as the Medicare and Medicaid programs.  Estimates of the amount of fraud and misspending in these programs vary widely, from $20 billion to as much as $100 billion. Just this week, testimony before the Senate Finance Committee underscored the seriousness of this problem, as witnesses testified that while much has been accomplished in the fight against fraud and abuse, much more needs to be done.  As Senators and members of the Finance Committee, we have a duty to ensure that taxpayer funds are being spent wisely.

Combating fraud in Medicare and Medicaid has long been a challenge for the Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services Inspector General (HHS OIG) and the Department of Justice (DOJ).  To date, numerous efforts have been made to reduce fraud, yielding a mixed record of successes and failures.  We believe federal efforts would be strengthened by input from members across the health care community – providers, payers, health plans, contractors, non-profit entities, consumers, data analytics entities, governmental partners, and patients. Drawing on the collective wisdom and accumulated insights of thousands of professionals and individual experiences could offer a fresh perspective and potentially identify solutions that may have been overlooked or underutilized.

Today we are announcing an effort to solicit ideas from all interested stakeholders in the health care community, regarding solutions and suggestions for how to better prevent and combat the multi-billion dollar problem of waste, fraud and abuse in the Medicare and Medicaid programs.  We invite you to submit white papers offering your best ideas, built on years of experience and insight.  We want to know what areas you see for improvement in current program integrity efforts, as well as additional solutions that we should consider. Working together, we hope to identify innovative solutions that will provide taxpayers with a better return on the investments being made to combat the overpayments in these federal health care programs.

Below are the general categories in which we seek input, though some recommendations may include multiple categories:

&#61623      Program Integrity Reforms to Protect Beneficiaries and Prevent Fraud and Abuse

&#61623      Payment Integrity Reforms to Ensure Accuracy, Efficiency and Value

&#61623      Fraud and Abuse Enforcement Reforms to Ensure Tougher Penalties Against Those Who Commit Fraud

 

Entities interested in submitting white papers should email a PDF or Microsoft Word document to ProgramIntegrityWhitePapers@finance.senate.gov by June 29, 2012.  Submissions should include summary information about the entity or individual submitting a white paper, as well as phone and email contact information. White papers should be as succinct and concrete as possible.  When possible, please include cost-benefit or potential savings information.  Our staff will review submissions and compile a summary document highlighting key proposals later this year.

We appreciate your submission of thoughtful and constructive solutions, as we work to conduct targeted oversight to improve federal efforts to reduce fraud and abuse in Medicare and Medicaid. Together, we believe we can improve program integrity and be better stewards of taxpayer dollars.

Sincerely,

BAUCUS
HATCH
COBURN
WYDEN
GRASSLEY
CARPER

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Angela Miller Speaking at AAOE Conference New Orleans May 2012


We are delighted to announce the course being presented by Angela Miller, President of Medical Auditing Solutions LLC: Developing Elements for an Effective Compliance Program, has been approved for 1 CEU through AAPC for your LIVE presentation. AAPC provides physician-based medical coders education and professional certifications.

American Association of Osteopathic Executives

Course Information:

Course Title:  Developing Elements for an Effective Compliance Program

Monday, 5/21/2012, from 3:15pm-4:30pm

Location: Hilton New Orleans Riverside  Room:  Belle Chase, subject to change

Register Now through the AAOE Conference Registration site:

http://www.aaoe.net/displaycommon.cfm?an=1&subarticlenbr=97

We look forward to seeing you at the conference and on the Riverboat Ride on Sunday, May 20, 2012. Call us to schedule an appointment to learn what we do or to learn what you need to ensure you have in place for your compliance program as well as your HIPAA Privacy & Security Programs.

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.

OIG Work Plan 2012


I participated in a call on Thursday January 19, 2012, on the OIG Work Plan for 2012.  Please reference the link for the full OIG Work Plan spelled out by provider type.  Many items on the Work Plan never change but there were a few points I felt important to draw your attention to for risk management purposes.  Here are a few notes I made because I think the audit risk is high since the result can be subjective:

1.  Outpatient Observation Billing

2.  Critical Access Hospitals:

A.  Distance to nearest, non-critical access hospital

B.  Herceptin and other Chemo Drug quantity

3.  Hospice because 82% of patients do not meet criteria to be admitted to hospice.

4.  Incident to Services by non-qualified personnel.  Even Blue Cross and Blue Shield is recouping and extrapolating on commercial claims for mid-level practitioner billing.  Make sure modifier is used when appropriate and the mid-level meets the licensing requirements to provide the services billed.

5.  Off Label Prescriptions.  Physicians ordering a drug that is approved for Diagnosis A but the drug is used for diagnosis B.

6.  Home Health-but not specific because they are going to review 2010 billing before they decide.

7.  Dialysis and ESRD Drug costs.  What is the drug cost to the provider versus the reimbursement.

8.  Contracts providers have with other providers/facilities.  Make sure you have a health care attorney to review the contract before executing because the health care attorneys are familiar with the Stark and Anti-Kickback provisions which typically the corporate business attorney does not have to consider.

9.  Checking employees, vendors, and providers against Sanction Databases MONTHLY.  You may find the federal links on my website.  The states have their own links.

10.  NY Medicaid reduced the annual revenues to $500K in Medicaid/Medicaid HMO/Managed Care Organizations (MCO) funds for compliance program requirement.

11.  Compliance Program Requirement under Federal Deficit Reduction Act that required all healthcare providers to have a compliance program in place by 2007 if their annual collected revenue of State reimbursement was $5M or more.  This would include Medicaid and respective Medicaid HMO or MCO.

12.  As of 2013 a healthcare compliance program is required for all providers billing Federal or State plans no matter what the annual billing revenue may be.  This would include dental practices because they bill Medicaid!

13.  Overpayments must be disclosed and refunded within 60 days of identification that it is an overpayment.  Failure to refund this money can result in “False Claims” charges and penalties.  Ensure you have someone that is accountable for working your credit balance reports monthly.  Keep documentation of these reviews and refunds issued as a result in a manner that can easily be explained and found.

The OIG Work Plan can be used to determine risk analysis, structure audit plans, and determine growth opportunities.

Do you have a Healthcare Compliance Program?

Do you review the OIG Work Plan Annually?

What else do you review to determine your audit plan?

We can help you analyze the status of your healthcare compliance program and ensure you have focused on the correct risks for your business model.  We are the compliance expert with a vast history and a cost effective way to ensure your compliance program is operating and managing your risk.

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.