Archive for October, 2012

CMS Updates Program Integrity Manual

CMS Update to Chapter 15 of the Program Integrity Manual
Part IX – Provider Enrollment

Effective date: November 20, 2012
Implementation date: November 20, 2012

Change request (CR) 8019 updates Chapter 15 of the Medicare Program Integrity Manual, which deals with Medicare provider enrollment There are several policy updates in this CR related to:

  • Correspondence addresses
  • Out-of-state practice locations
  • Submission of change of ownership (CHOW) applications after an initial or CHOW application has been submitted, and
  • The scope of revocations and re-enrollment bars.

Read the full details at MLN Matters.

The Next Generation of Corporate Integrity Agreements

On August 7, 2012, the Office of the Inspector General (OIG) held a roundtable meeting with representatives from 32 companies that have entered into Corporate Integrity Agreements (CIA) since 2009.  The OIG will consider feedback when deciding what terms to include in future CIA’s.

The roundtable involved small-group discussions of several topics: (1) the definitions of “covered persons” and “relevant covered persons” and CIA requirements relating to a code of conduct, compliance policies and procedures, and training and education; (2) the role of the compliance officer, internal auditing and audit plans, and the role of the board of directors; (3) claims review requirements; and (4) arrangements. 

You may read the entire OIG article here.

Documentation Deficiencies

Seventy percent of plain film studies, computed tomography, and magnetic resonance imaging scans did not follow one or more documentation practice guidelines promoted by the American College of Radiology (ACR), according to a 2008 Office of Inspector General (OIG) report. Three major documentation deficiencies missing from the interpretation and reports as noted by the OIG were: the time the exam was performed, the time the report was dictated and the date the report dictated.

Medicare expects the radiologist’s report (may be on separate paper or within the body of the patient’s record) to follow the ACR  guidelines. Documentation is essential to establish that the results of the interpretation and report were communicated in a timely manner to the treating physician in the emergency department. Radiology providers should review their current documentation practices. The ACR Practice Guideline for Communication of Diagnostic Imaging Findings may be found here.

Fiscal Year 2013 HHS OIG Work Plan

 The HHS Office of Inspector General (OIG) Work Plan for Fiscal Year 2013 provides brief descriptions of activities that OIG plans to initiate or continue with respect to HHS programs and operations in fiscal year 2013.

The Work Plan describes the primary objectives and provides for each review its internal identification code, the year in which we expect one or more reports to be issued as a result of the review, and indicates whether the work was in progress at the start of the fiscal year or will be a new start during the year.

Click here to read more.