Category Archives: Supplier

OIG Publishes Special Fraud Alert regarding Physician-Owned Distributors (“PODs”) – Describes PODs as “Inherently Suspect”

Posted on April 16, 2013 by | Comments Off

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 →

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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

Spring Cleaning – Dust Off Your Compliance Program Manual and Take Some Practical Steps to Reinvigorate Your Program.

Posted on March 22, 2013 by | Comments Off

Compliance program fatigue is nothing new. Over at least the last 15 years, health care organizations have jumped in head first, put together detailed manuals and taken the plunge. However, reimbursement cuts, quality initiatives, RACs, ZPICs, whistleblowers, physical plant renovations and simply significant industry challenges got in the way of sustaining an efficient and effective compliance effort. Health care organizations have also become desensitized to the barrage of compliance education, enforcement press releases, audits and reviews and other shock-value communications on the importance of regulatory compliance. In that vein, this very article may get lost in the shuffle, although, we hope it doesn’t.

An efficient and effective compliance effort with your organization is extremely important, if only as an insurance policy against government scrutiny. Additionally, the Patient Protection and Affordable Care Act of 2010, H.R. 3590 (“ACA”) includes requirements that CMS implement mandatory compliance program requirements for all providers and suppliers. In a distinct section of ACA, nursing home mandatory compliance programs were given a specific implementation timeline. Continue reading →

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Posted in Acute Care, Adult Home, Ambulatory Surgery Centers, Assisted Living, Clinical Laboratory, Clinics, Community Based Care, Compliance Programs, Continuing Care, Diagnostic Testing, Disability, Durable Medical Equipment, Fraud and Abuse, Group Home, Health Care, Health Care Providers, Health Information Privacy, Health Reform, Home Health, Hospice, Hospital, Intermediate Care Facility, Long Term Care, Long Term Care Hospital, Medicare, Mental Health, Nursing Facility, Nursing Home, Occupational Therapy, Out-Patient Care, Palliative Care, Pharmacy, Physicial Therapy, Physician Assistants, Physicians, Post Acute Care, Primary Care, Program Integrity, Regulatory Compliance, Rehabilitation, Rehabilitation Hospital, Residential Care, Senior Housing, Skilled Nursing Facility, Supplier

Revised Advance Beneficiary Notice Use Now Required

Posted on January 13, 2012 by | Comments Off

The revised Advance Beneficiary Notice (ABN) form is now required as of January 1, 2012.  The ABN form is provided to Medicare beneficiaries by providers such as skilled nursing facilities, physicians and others when the provider believes that Medicare may not cover and reimburse the services to be provided.  This notice of noncoverage is provided to the beneficiary and the revised notice Form CMS-R-131 can be accessed through the attached link with additional information on its use.  http://www.cms.gov/BNI/02_ABN.asp

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Posted in Continuing Care, Durable Medical Equipment, General, Health Care, Health Care Providers, Home Health, Hospital, Long Term Care, Medicare, Nursing Facility, Occupational Therapy, Out-Patient Care, Physicial Therapy, Physicians, Post Acute Care, Rehabilitation, Skilled Nursing Facility, Supplier

CMS Issues – MLN Matters on Expansion of Durable Medical Equipment (DME) Supplier Standards

Posted on February 2, 2011 by | Comments Off

On 2/1/2011, CMS Issued MLN Matters No. SE1032 entitled “Expansion of Durable Medical Equipment (DME) Supplier Standards” 

The article provides information for DMEPOS suppliers on the new expanded CMS enrollment standards that suppliers must meet in order to establish and/or maintain billing privileges in the Medicare Program. Continue reading →

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Posted in Durable Medical Equipment, General, Medicare, MLN Matters, Provider Enrollment - Medicare, Supplier