In a recently released MLN Matters (Number: SE1417), CMS announced that it is implementing the enhanced enrollment screening provisions of the Affordable Care Act (ACA) by requiring finger print based background checks for certain so called “high risk” providers. Currently this means that for newly enrolling Durable Medical Equipment, Prosthetic, Orthotic and Supplies (DMEPOS) suppliers and Home Health Agencies, individuals with a 5% or greater ownership interest in the provider or supplier will be subject to criminal background checks based on fingerprint identification. The procedure will also apply to providers that CMS has elevated to the high risk category pursuant to regulations. Affected providers will be notified by their MAC and be given 30 days to comply. The notification will identify contact information for the Fingerprint Based Background Check Contractor (FBBC). Continue reading
Posted in Community Based Care, Compliance Programs, Durable Medical Equipment, Employee Background Checks, Fraud and Abuse, General, Health & Human Services, Health Care, Health Care Providers, Health Reform, Home Health, Medicare, MLN Matters, Participation, Program Integrity, Provider Enrollment - Medicare, Regulation, Regulatory Compliance
On February 20, 2014, the US Department of Health and Human Services, Departmental Appeals Board upheld CMS’ revocation of the Medicare provider number of a clinic/group practice.
In Advanced Care Medical Center v CMS (Docket No. C-13-1383/Decision No. CR3124), the DAB, Civil Remedies Division upheld CMS’ revocation of Advanced Care’s Medicare provider number.
The matter began with an investigation by the Office of the Inspector General which revealed that Advanced Care entered into a contract with a doctor, allowing him to bill for services under it’s billing number in exchange for a set reimbursement, and the doctor submitted bills under Petitioner’s billing number. Continue reading
Posted in Certification, Community Based Care, Compliance Programs, DAB Decisions, DHHS, Fraud and Abuse, Health & Human Services, Health Care, Health Care Providers, Medicare, Out-Patient Care, Participation, Physicians, Program Integrity, Provider Enrollment - Medicare, Regulatory Compliance
On February 4, 2014, the Centers for Medicare and Medicaid Services (CMS) issued in the Federal Register a notice of temporary moratoria on enrollment of new home health agencies (HHA) and ambulance suppliers and providers in certain geographic locations across the U.S. The moratoria were effective on January 30, 2014. CMS also extended existing moratoria noticed on July 31, 2013. Continue reading
Posted in Ambulance, Certification, Community Based Care, Florida, Fraud and Abuse, General, Health & Human Services, Health Care, Health Care Providers, Home Health, Illinois, Medicaid, Medicare, Michigan, New Jersey, Participation, Post Acute Care, Program Integrity, Provider Enrollment - Medicaid, Provider Enrollment - Medicare, Regulation, States, Texas, Transportation
Earlier this month, the Centers for Medicare and Medicaid Services (“CMS”) released a policy memorandum announcing stricter Medicare certification practices for buyers of Medicare-participating providers opting to reject the automatic assignment of the seller’s Medicare provider contracts. When a purchaser is considering opting out of automatic assignment, it must carefully weigh the risk of reimbursement gaps with the benefit of reduced liability exposure. Continue reading
Posted in Certification, CMS Transmittals, Health & Human Services, Health Care, Health Care Providers, Medicare, Participation, Provider Enrollment - Medicare, Regulatory Compliance, Reimbursement, Survey and Certification Letters
On April 10, 2012, the GAO released a report (GAO-12-351) entitled Medicare Program Integrity – CMS Continues to strengthen the Screening of Providers and Suppliers. The report focusses on many of the ongoing Medicare program integrity initiatives that CMS has been implementing and that are required by the Patient Protection and Affordable Care Act (“PPACA”).
The GAO specifically looked at Medicare provider enrollment procedures. The GAO report focused on: (1) how CMS and its contractors use provider and supplier enrollment information to prevent improper payments and factors that may affect the usefulness of this information, and (2) the extent to which CMS has implemented new provider and supplier enrollment screening procedures since the enactment of PPACA. Continue reading
Posted in Certification, Compliance Programs, DHHS, Fraud and Abuse, Health & Human Services, Health Care, Health Care Providers, Health Reform, Medicare, Participation, Program Integrity, Provider Enrollment - Medicare, Regulatory Compliance, Reimbursement
On April 6, 2012, CMS issued a memorandum to state survey agency directors (S&C: 12-26-HHA) informing them that, effective immediately, Home Health Agencies (HHAs) that have had their billing privileges deactivated must undergo recertification surveys before billing privileges can be reinstated. The change in policy was enacted with the The Home Health Prospective Payment System (HHPPS) final rule CMS-1560-F, which amended 42 C.F.R. 424.540(b)(3), effective January 1, 2010.
As CMS noted, a deactivation of billing privileges most commonly occurs when the provider fails to submit a Medicare claim for 12 consecutive months. During the deactivation period, the HHA’s Medicare provider agreement remains in place and the HHA will retain the same CMS Certification Number (CCN) once the recertification survey has been completed. No new provider agreement will be required.
For the full text of the Survey and Certification Letter, please see —> S&C: 12-26-HHA
Posted in Certification, Community Based Care, Health Care, Health Care Providers, Home Health, Medicare, Participation, Program Integrity, Provider Enrollment - Medicare, Regulatory Compliance, Survey and Certification Letters
On February 8, 2012, the Office of Inspector General (“OIG”) released an alert warning physicians to exercise caution when reassigning their right to bill and receive payment from the Medicare program. According to the OIG, Physicians who reassign their Medicare provider benefits by executing a CMS-855R application may be held liable for false claims submitted by the assignee. Continue reading