Compliance

Two recent reports should make providers stop, take notice and make sure their practice's policies and procedures are up-to-date.

How to Properly Report Prolonged Evaluation and Management Services

Have you ever had a patient take more time with the provider than they were scheduled for? Do you understand which codes to report and the rules that govern them to allow for better reimbursement?

Healthcare providers must be vigilant in ensuring that software upgrades, also known as patches, are kept current. Failure to do so can lead to a HIPAA Security Breach with all its associated penalties. For example Windows XP no longer has security updates and should not be used in healthcare settings.

On January 17, 2018, the OCR released another known problem with the chips on some computers. The notice stated:

Healthcare and Public Health Sector partners-

60 Day Final Rule

Effective March 14, 2016, the CMS Final Rule regarding the reporting of overpayments took effect. This ruling clarifies the standards that have been unclear for years since the the PPACA created what is called the "60-day rule." The problem has been the unclear standards on what it means to "identify" an overpayment and when the 60 day clock begins running.

Now, the 60-day rule requires anyone who has received an overpayment from either Medicare or Medicaid to report and return the overpayment within the latter of:

It is important for providers to understand the critical nature of the Business Associate Agreement (BAA). Far too many healthcare providers are neglecting this component of HIPAA, which can be a costly mistake. For years providers have been warned that if they are a HIPAA Covered Entity (CE) they MUST have properly executed BAAs for all their business associates. Failure to do so could cost millions. Penalties begin at $50,000 per violation with a maximum of $1.5 million per year for repeats of the same violation.

NAMAS Weekly Auditing and Compliance Tips

Combined Deskbook Resources

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What is an Other Qualified Healthcare Professional?

To begin to answer this question, let's review the exact wording in the CPT codebook:

Many healthcare organizations are not aware of how critically important it is to screen their employees against ALL state and federal exclusions databases. The OIG is reviewing organizations in ALL federal healthcare programs - this includes Medicare, Medicaid, CHIP, etc. - for those who have employed individuals on ANY exclusions database. Not only must you screen employees on the OIG Exclusions database, but employers are also responsible to check state exclusions databases as well.

Employee Exclusions Screenings Must be High Priority

Many healthcare organizations are not aware of how critically important it is to screen their employees against ALL state and federal exclusions databases. The OIG is reviewing organizations in ALL federal healthcare programs - this includes Medicare, Medicaid, CHIP, etc. - for those who have employed individuals on ANY exclusions database. Not only must you screen employees on the OIG Exclusions database, but employers are also responsible to check state exclusions databases as well.

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