On November 6, 2013, CMS issued Transmittal No. 1311 which instructed Medicare Administrative Contractors (“MACs”) to reject claims for SNF to SNF ambulance transfers that are billed separately under Part B. According to CMS, ambulance transportation and related ambulance services for residents in a Part A stay are included in the SNF PPS rate and may not be billed as Part B services by the supplier. Instead, the SNF discharging the beneficiary to another SNF is responsible for the transportation fees. As such, ambulance providers must seek payment from the transferring SNF. Continue reading
Posted in Ambulance, CMS Transmittals, Continuing Care, Health & Human Services, Health Care, Health Care Providers, Long Term Care, Medicare, Nursing Facility, Nursing Home, Post Acute Care, Program Integrity, Regulatory Compliance, Skilled Nursing Facility, Transportation
Last week, Ohio Medicaid Director John McCarthy announced that the launch date for voluntary enrollment in MyCare Ohio (fka as Ohio’s Integrated Care Delivery System) will be delayed until March 1, 2014. The announcement was made during Director McCarthy’s recent testimony before the Joint Legislative Commission for Unified Long Term Care Services and Supports. Continue reading
Over the last several years, there has been a noted proliferation in the growth of physician-owned distributors (“PODs”). Along with this growth has come increased scrutiny and speculation as to the legality of PODs, with highly vocal critics and proponents on both sides of the debate. In fact, the Office of the Inspector General’s (“OIG”) 2013 Work Plan noted that the OIG planned to examine PODs in connection with reports of high utilization of spinal implants by hospitals associated with PODs.
Accordingly, on March 26, 2013, the OIG released a Special Fraud Alert (the “Fraud Alert”) which provides long-awaited guidance concerning the legality of PODs. Continue reading
Posted in Anti-Kickback, DHHS, Fraud and Abuse, Health Care, Health Care Providers, OIG, Out-Patient Care, Physicians, Primary Care, Program Integrity, Regulatory Compliance, Special Fraud Alert, Supplier
On October 2, 2012, The U.S. Department of Health and Human Services Office of the Inspector General (“OIG”) released its Work Plan for 2013. The OIG releases its work plan for each year in advance of the coming year. The work plan provides stakeholders in the health care industry with a broad overview of the OIG’s activities in the coming year as they relate to its enforcement priorities and issues it will review and evaluate during that fiscal year. This client alert is the second in a series of alerts that will outline the OIG’s activities, as discussed in the 2013 Work Plan, for a specific industry sector – Nursing Homes.
The OIG’s activities relating to Nursing Homes for 2013 are focused on quality of care, although investigations concerning questionable billing patterns are once again identified as a priority. Continue reading
Posted in Compliance Programs, Fraud and Abuse, Health Care Providers, Medicaid, Medicare, Nursing Facility, Nursing Home, OIG, OIG Work Plans, Regulatory Compliance, Skilled Nursing Facility