Compliance Programs Required 3/25/2013

Well, we thought with Health Care Reform Act of 2010 that providers had 3 years from the signature date to have a plan implemented. With the final provisions of the Patient Protection Affordable Care Act, you have until 3/25/2013…less than 2 months to have a compliance plan in place.   They make reference to the 7 element compliance program currently recommended as a basis for the program structure. The final rule has language that reads as though they will withhold payment to providers that do not have compliance program in place.  Don’t worry, we can help you with a simple compliance program that is affordable.

A few other items that impact business decisions. This takes effect 3/25/2011 for all new providers and March 2012 for all existing providers.

1.  Moratorium on Medicare, Medicaid & CHIP provider numbers based on products and number of suppliers in the area.  This may not be as easy anymore.

2.  Application fees of $500 each for all providers excluding physicians and nurse practitioners and their group practices. If a provider applied for Medicare and Medicaid then only one fee will be required, but proof of Medicare application may be required.

3.  New screening and Fingerprinting requirements. Note Florida has had fingerprinting in place for over 8 years. You have to have a criminal record and there are many fraudulent providers that currently do not have a record. This applies to owners of 5% or more of the company, directors and officers.

4.  Unscheduled & unannounced visits to check up on suppliers.

5.  Re-enrollment for Medicare every 3 years and Medicaid annually and fees will apply plus inflation rate for CPI.

6.  New state licensing requirements to come from this also.

If you do not have a compliance program or haven’t taken your seriously, it is a requirement that could result in suspended payments.

With proven experience in the health care compliance, We can help you with a compliance program policies and procedures as well as teach you to manage your program or help you manage the program to ensure you pass the government inspection to ensure effect within 3 years of implementation. They can request random audits for privacy and security to ensure you are meeting requirements and now they have added billing compliance.

We can also help you with provider applications to ensure they are done right the first time.

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.

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Numerous Physician, Physician Groups, and DME Revocations Coming

The American Health Lawyers listserv released yesterday, there are numerous revocations across physician, physician groups, and DME providers for failure to respond to 855 validation or update requests or the provider was not open or available during a sight visit.  Please ensure you or your staff open mail in a timely manner!  Be sure you take immediate action on any requests from Medicare.  Medicare periodically requests for updates, validation or new 855 payor applications be completed. If the Medicare contractor does a sight visit, you must have hours posted and the door must be unlocked and the person greeted, if it is during your business hours.   Likewise, if you are closed for vacation, post a sign on the door & answering service vacation dates and who patients should see in an emergency.  This may have come as a PECOS notice.  Think of PECOS as your online 855 submission and application management.  Educate your staff to review mail timely and notify you immediately of any requests from Medicare for any response, forms, documentation.  You as the business owner need to review it or have it reviewed.

It seems every time  we turn around there is bad news to deliver to health care providers.  This is a very scary time from audits, revocations, reimbursement cuts along with legible documentation and getting patients to come into the office for an in-person visit when they are physically not capable.  The industry is facing challenges.

Medicare must be notified if you move because they mail requests to the address on file.  Remember, an invalid telephone number or area code can result in revocation as well.  Likewise, the post office does not always deliver the mail and they do not send communication with a tracking number!

You have 30 days to submit a corrective action plan, but be proactive and do it immediately!  The Corrective Action Plan form can be located via the MAC contractor website.  If the Correction Action Plan is denied, there is no appeal!

It is crucial for you to keep your provider number because without it you will not be reimbursed and are subject to loosing other payor contracts. You have to get your number placed in good standing, but this can be a long process.  They also do not have to activate it back to the date it was turned off.  If you need help completing or validating the 855 application or working an appeal, we can help you in a cost effective manner.   We work with several health care law firms that can assist you also.  Be sure no matter who you have help you, they have experience with the application process, understand the health care industry and/or are health care attorneys.

I feel like I need to have a drink or joke of the week blog so I can bring some good uplifting news.

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.  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.