The Final Overpayment Rule and Practical Steps for Compliance

By: James Saling

On February 11, 2016, the Center for Medicare and Medicaid Services (CMS) issued the final overpayment rule commonly referred to as the “60 Day Rule”. Physicians, labs, hospitals, and other providers that receive reimbursement under Part A or B must comply with the 60 Day Rule or face penalties under the False Claims Act.

The 60 Day Rule requires that overpayments (e.g., payment for coding errors) be reported and returned to CMS within 60 days after the date on which the overpayment was identified. Identification of the overpayment was addressed at length in the regulation.  The 60-day clock to identify overpayments starts ticking “when the person has, or should have through the exercise of reasonable diligence, determined that the person has received an overpayment and quantified the amount of the overpayment.”  Reasonable diligence means that the provider takes steps to uncover overpayments and steps to quantify the amount of the overpayment.Continue reading

ASAM & Cigna to Collaborate on Performance Measures in Addiction Treatment

Recruitment and Retention Agreements

cigna asamBy: Karina Gonzalez

ASAM and announced a collaborative effort with  Brandeis University to test and validate three ASAM performance measures for addictions treatment. ASAM hopes that this project will provide measure testing of performance measures that will be accepted and adopted in the treatment of patients with addiction.

Three measures will be tested using two years of de-identified Cigna claims data  for  substance abuse.  The measures to be  tested in the study will be: use of pharmacotherapy for individuals with alcohol use disorders; pharmacotherapy for individuals with opioid use disorders and follow-up after withdrawal.  This is expected to be a six month project.Continue reading

Medicare Liability (and more) Buyer Beware

telehealth payment

By: Jeff Cohen

Healthcare businesses are bought and sold every day!  Though sophisticated people are fully aware of the risk difference between an entity sale and an asset sale, some do not understand the lingering nature of Medicare related liability.

When a legal entity (company, limited liability company, whatever) is bought, the liabilities of that entity are often assumed by the buyer.  This is because buyers that purchase selling healthcare entities like the idea of keeping both term managed care agreements and the Medicare provider number intact.  Keeping them intact can help ensure continual cash flow of the seller, but will also create Medicare liability to the buyer. Continue reading

Substance Abuse Treatment: The First Step in Generating Revenue

By: Urgent Medical Billing, Guest Contributor

The first step in generating revenue for a substance abuse treatment facility is pre-screening potential clients for the level of care they will meet criteria for. This includes, but is not limited to:

– gathering current and historical information including drug of choice;
– drug history (what drugs, how much, how often, first use, last use and route);
– drug treatment history and levels of care the client has already participated in;
– medical history including past history of seizures, black outs and any other direct/indirect consequences of the client’s drug abuse/dependence;
– family history of drug abuse;
– medications that client is currently on; and
– history of being on psychotropic medications/past mental health diagnosis.

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