AHLA. BB. Rules of the Road in Investigating and Disclosing Overpayments. Tiana L. Korley Principal Healthcare Fraud Analyst Mitre Windsor Mill, MD
|
|
- Chrystal Pierce
- 5 years ago
- Views:
Transcription
1 AHLA BB. Rules of the Road in Investigating and Disclosing Overpayments Tiana L. Korley Principal Healthcare Fraud Analyst Mitre Windsor Mill, MD Jesse A. Witten Drinker Biddle & Reath LLP Washington, DC Fraud and Compliance Forum October 6-7, 2014
2 Rules of the Road in Investigating and Disclosing Overpayments Tiana L. Korley AHLA Fraud and Compliance Institute October 6-7, 2014 Disclaimer 2 The author s affiliation with the MITRE Corporation is provided for identification purposes only, and is not intended to convey or imply MITRE s concurrence with, or support for, the positions, opinions or viewpoints expressed by the author. 1
3 3 Discussion Topics Identifying an overpayment Special considerations Medicaid Part C and Part D Self-Referral Status of rulemaking Practical considerations Current enforcement actions 4 What is an overpayment? Statutory definition at 1128J(d) Proposed rule provides examples Medicare payments for noncovered services Medicare payments in excess of the allowable amount for an identified covered service Errors and nonreimbursable expenditures in cost reports Duplicate payments Receipt of Medicare payment when another payor had the primary responsibility for payment 2
4 When is an overpayment identified? 5 A person has identified an overpayment if the person has actual knowledge of the existence of the overpayment or acts in reckless disregard or deliberate ignorance of the existence of the overpayment. Reopening Period 6 Revised to be commensurate with 10 year lookback Consider impact of new legislation to expand recovery period Section 638 American Taxpayer Relief Act of 2012 Designed to ensure recovery period exceeds reopening period in response to OIG concerns Also likely included for scoring purposes Saves $500 million over 10 years Outstanding Question - If 10 year lookback period is finalized and reopening rules are amended, would Congress subsequently amend statutory provision to ensure recovery period extends to at least 10 years? Does it matter? 3
5 7 Medicaid Incentives vary depending upon fee for service vs. managed care GAO Report May 2014: Increased Oversight Needed to Ensure Integrity of Growing Managed Care Expenditures OIG Management Challenge 4: Protecting the Integrity of an Expanding Medicaid Program Specifically addresses Medicaid managed care How to return overpayments/information reporting States usually have substantial discretion Will we have 56 different methodologies? Government s position expressed in proposed rule is that there is an existing obligation to report and return Medicaid-related overpayments in a manner consistent with the statutory provision 8 Parts C/D Considerations An overpayment exists when, after "applicable reconciliation," an MA organization or Part D sponsor is not entitled to the funds it has received and retained. Applicable reconciliation" definition For MAOs, the "applicable reconciliation" date will be the final risk adjustment data submission deadline, which effective July 22, 2014, will be set for January 31 of the year following the payment year. For Part D, the "applicable reconciliation" date will be the later of either the annual deadline for submitting prescription drug event (PDE) data, or the annual deadline for submitting direct and indirect remuneration (DIR) data. Provision not nearly as controversial as Part A/B proposed rule Received only 30 timely comments on NPRM section 4
6 Self-Referral Overpayments 9 SRDP vs MAC Tolling of obligation to return overpayment Due to length of time it takes to resolve overpayments disclosed under SRDP, there may be a substantial amount of uncertainty Proposed legislation to expedite return of certain Self-Referral overpayments Form-related revisions may smooth this process Forms do not appear to capture all of the required information in the proposed regulation Perhaps timing is an issue Consider refunding small amounts to the MAC due to SRDP timing and cost But does existing reporting form capture this nuance? There may be an other line in at least some forms related to reason for the voluntary refund; does reporting as other absent additional information trigger additional scrutiny? Reaction to Proposed Rule 10 5
7 11 Status of Rulemaking Parts A/B Published NPRM February 2012 Statutory deadline for final rule February 2015 Included in Spring Unified Agenda (CMS-6037-F) Parts C and D Final rule published May 2014 Outstanding Questions Special form for A/B returns Content of form for collection for Medicaid overpayments will this be standardized? How will government utilize this provision to recover overpayments? 6
Medicare Overpayments: Analyzing the CMS 60-Day Rule
Presenting a live 90-minute webinar with interactive Q&A Medicare Overpayments: Analyzing the CMS 60-Day Rule Reporting and Refunding Overpayments for Providers, Suppliers, Drug Plan Sponsors, and Medicaid
More informationGoals for Today s Presentation
AMERICAN HEALTH LAWYERS ASSOCIATION Institute on Medicare and Medicaid Payment Issues March 20-22, 2013 Baltimore, Maryland Medicare and Medicaid Overpayments and Refunds Presented by: Robert L. Roth,
More informationAgenda. Strategic Considerations in Resolving Voluntary Government Disclosures
Strategic Considerations in Resolving Voluntary Government Disclosures Health Care Compliance Association Annual Compliance Institute Patrick Garcia Hall, Render, Killian, Heath, & Lyman, P.C. Kenneth
More information2/24/2017. Agenda. Determine Potential Liability. Strategic Considerations in Resolving Voluntary Government Disclosures. Relevant legal authorities:
Strategic Considerations in Resolving Voluntary Government Disclosures Health Care Compliance Association Annual Compliance Institute Patrick Garcia Hall, Render, Killian, Heath, & Lyman, P.C. Kenneth
More informationDEPARTMENT OF HEALTH AND HUMAN SERVICES. Medicare Program; Reporting and Returning of Overpayments
This document is scheduled to be published in the Federal Register on 02/16/2012 and available online at http://federalregister.gov/a/2012-03642, and on FDsys.gov CMS-6037-P DEPARTMENT OF HEALTH AND HUMAN
More informationGoals for Today s Presentation
AMERICAN HEALTH LAWYERS ASSOCIATION Institute on Medicare and Medicaid Payment Issues March 26-28, 2014 Baltimore, Maryland Medicare and Medicaid Overpayments and Refunds Presented by: Robert L. Roth,
More informationRepay Overpayments (18 USC 1347; 42 CFR et seq.)
Repay Overpayments (18 USC 1347; 42 CFR 401.301 et seq.) Repaying Overpayments If provider has received an overpayment, provider must: Return the overpayment to federal agency, state, intermediary, or
More informationIt s Here: The Final 60 Day Overpayment Rule
It s Here: The Final 60 Day Overpayment Rule (What it means for you and your clients) Hillary M. Stemple, Esq. Associate Arent Fox LLP Washington, DC 20006 hillary.stemple@arentfox.com December 5, 2017
More informationAHLA. L. Medicare Advantage New Developments and Key Legal Issues. Anne W. Hance McDermott Will & Emery LLP Washington, DC
AHLA L. Medicare Advantage New Developments and Key Legal Issues Anne W. Hance McDermott Will & Emery LLP Washington, DC Institute on Medicare and Medicaid Payment Issues March 26-28, 2014 Recent Developments
More informationMedicare Overpayment 60 Day Rule
Medicare Overpayment 60 Day Rule What Your Compliance and Auditing Departments Need to Know Objectives Review the key legal, operational and technical takeaways from the ACA 60 Day Report and Repay Statute.
More informationThe 60-Day Rule: When Does the Clock Start Ticking After the Kane Ruling? September 3, 2015
The 60-Day Rule: When Does the Clock Start Ticking After the Kane Ruling? September 3, 2015 Laura Keidan Martin National Chair, Health Care Practice Group Katten Muchin Rosenman LLP 312.902.5487 laura.martin@kattenlaw.com
More informationCMS 60-Day Rule: Reporting and Refunding Overpayments for Providers and Suppliers One Year Later
Presenting a live 90-minute webinar with interactive Q&A CMS 60-Day Rule: Reporting and Refunding Overpayments for Providers and Suppliers One Year Later WEDNESDAY, APRIL 5, 2017 1pm Eastern 12pm Central
More informationCMS 60-Day Rule: Reporting and Refunding Overpayments, Enforcement, Compliance, Self-Disclosure
Presenting a live 90-minute webinar with interactive Q&A CMS 60-Day Rule: Reporting and Refunding Overpayments, Enforcement, Compliance, Self-Disclosure THURSDAY, SEPTEMBER 13, 2018 1pm Eastern 12pm Central
More informationCan Negligence Really Trigger False Claims Act Exposure?
What s the Future of the CMS 60-Day Overpayment Rule? Can Negligence Really Trigger False Claims Act Exposure? Barbara Rowland Washington, D.C. Office Chair Internal Investigations & White Collar Defense
More information3/17/2015. HCCA Compliance Institute April 19, Legal Obligations to Disclose and Refund. Background on Government Approach to Overpayments
HCCA Compliance Institute April 19, 2015 Exploring CMS s Proposed Rule on Reporting and Refunding Overpayments Gary W. Eiland, Partner King & Spalding LLP Houston, Texas Background on Government Approach
More informationRACs and Beyond. Kristen Smith, MHA, PT. Peter Thomas, JD Ron Connelly, JD Christina Hughes, JD, MPH. Senior Consultant, Fleming-AOD.
RACs and Beyond Kristen Smith, MHA, PT Senior Consultant, Fleming-AOD Peter Thomas, JD Ron Connelly, JD Christina Hughes, JD, MPH The Powers Firm RACs and Beyond Objectives Describe the various types of
More informationSelf-Disclosure: Why, When, Where and How
American Bar Association Washington Health Law Summit Self-Disclosure: Why, When, Where and How December 8, 2015 Margaret Hutchinson U.S. Attorney s Office for the Eastern District of Pennsylvania Kaitlyn
More informationFebruary Six Key Themes. 2. The lookback period is six years. 1 We will be conducting a Webinar series in the coming weeks to explore the Final
in the news Health Care February 2016 60-Day Overpayment Reporting Final Rule The Rule of Six 1 O n February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule).
More informationReporting and Returning Overpayments. The 60-Day Repayment Window
Reporting and Returning Overpayments The 60-Day Repayment Window James A. Robertson, Esq. jrobertson@mdmc-law.com John W. Kaveney, Esq. jkaveney@mdmc-law.com Affordable Care Act requires: A person Who
More informationThe 340B Program: Challenges and Opportunities
The 340B Program: Challenges and Opportunities March 2015 Thomas Barker Igor Gorlach Foley Hoag LLP Overview Overview and History of the 340B Program ACA s Changes to the 340B Program Recent Developments
More informationFundamentals and Practicalities of Identifying and Returning Overpayments
Fundamentals and Practicalities of Identifying and Returning Overpayments American Health Lawyers Association Physicians and Physician Organizations Law Institute Hospitals and Health Systems Law Institute
More informationFAST BREAK : STARK LESSONS FOR PHYSICIAN PRACTICE ACQUISITIONS Albert Shay, Eric Knickrehm, and Jake Harper August 23, 2018
FAST BREAK : STARK LESSONS FOR PHYSICIAN PRACTICE ACQUISITIONS Albert Shay, Eric Knickrehm, and Jake Harper August 23, 2018 2018 Morgan, Lewis & Bockius LLP Agenda What is the Stark Law and what kind of
More informationStark Self-Disclosure. Thomas S. Crane 1/ Mintz Levin Cohn Ferris Glovsky and Popeo, PC
Stark Self-Disclosure Thomas S. Crane 1/ Mintz Levin Cohn Ferris Glovsky and Popeo, PC A. Background 1. Stark Law The Physician Self-Referral Statute (or the Stark Law ) prohibits a physician from referring
More informationMMA Mandate: Medicare Contract Reform
MMA Mandate: Medicare Contract Reform Julie E. Chicoine, JD, RN, CPC The Ohio State University Medical Center julie.chicoine@osumc.edu Medicare Program Created in 1965 Part A: Facilities, including hospitals
More informationRe: Medicare Program; Reporting and Returning of Overpayments, CMS-6037-P, RIN 0938-AQ58, Federal Register, Thursday, February 16, 2012.
Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-6037-P Mail Stop C4-26-05 7500 Security Boulevard Baltimore, MD 21244-1850 Re: Medicare Program; Reporting
More informationPart II: Medicare Part C and Part D
Part II: Medicare Part C and Part D Part II: Part C and Part D Part C (Medicare Advantage)... 1 Enhanced Payments to Plans for Certain Beneficiary Types... 1 Special Needs Plans: Enrollment of Medicare
More informationPhysician Relationship Compliance Issues
Physician Relationship Compliance Issues Charles Oppenheim Hooper, Lundy & Bookman, PC Overview of Anti-Kickback Statute It is a federal crime to: Knowingly and willfully offer or pay/solicit or receive
More informationPhysician Relationship Compliance Issues. Charles Oppenheim Hooper, Lundy & Bookman, PC
Physician Relationship Compliance Issues Charles Oppenheim Hooper, Lundy & Bookman, PC Overview of Anti-Kickback Statute It is a federal crime to: Knowingly and willfully offer or pay/solicit or receive
More informationAHLA. T. Legal and Practical Considerations for Internal Payment Audits. Timothy P. Blanchard Blanchard Manning LLP Orcas, WA
AHLA T. Legal and Practical Considerations for Internal Payment Audits Timothy P. Blanchard Blanchard Manning LLP Orcas, WA Beth DeLair President DeLair Consulting SC Middleton, WI Fraud and Compliance
More informationOIG and CMS Voluntary Self Disclosures: Weighing the Risks and Rewards of Self Reporting
Presenting a live 90-minute webinar with interactive Q&A OIG and CMS Voluntary Self Disclosures: Weighing the Risks and Rewards of Self Reporting WEDNESDAY, SEPTEMBER 24, 2014 1pm Eastern 12pm Central
More informationCertifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two
Certifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two Corporate Integrity Agreement Effective 4/23/2015 Term of five years Basic Requirement: Maintain a Compliance Program
More informationThe Stark Law and Self-Disclosure:
The Stark Law and Self-Disclosure: What Should You Do After Discovering a Potential Stark Violation? Healthcare Horizons Webinar Series September 25, 2012 Husch Blackwell LLP Welcome Brian Bewley, Partner
More informationStark Self-Referral Disclosure Protocol
Stark Self-Referral Disclosure Protocol What It Says, What It Means, and What It Holds for the Future Friday, October 1, 2010 Attorney Advertisement Prior results do not guarantee a similar outcome Models
More informationMEDICARE PART D PRESCRIPTION DRUG EVENTS (PDE) RECONCILIATION
MEDICARE PART D PRESCRIPTION DRUG EVENTS (PDE) RECONCILIATION 2-06-15 Presented by: Alexander Luong, Pharm.D. Candidate 2015 University of the Pacific Preceptor: Dr. Craig Stern, Pharm.D. MBA President,
More informationOber Kaler Health Law Client Alert
2014 Ober Kaler Health Law Client Alert CMS Self-Disclosure Protocol Overview, Practical Tips and Summary of Settlements Prepared by: Catherine A. Martin 1 Principal, Ober Kaler camartin@ober.com 410.347.7320
More informationMedical Loss Ratio. Institute for Health Plan Counsel May 8, Presenters:
Medical Loss Ratio Institute for Health Plan Counsel May 8, 2013 Presenters: Melissa J. Hulke, CPA, ABV, CFF Navigant, Phoenix, AZ melissa.hulke@navigant.com Scott O. Jones, FSA, MAAA Milliman, Seattle,
More informationDeciphering the Self-Disclosure Puzzle
Deciphering the Self-Disclosure Puzzle ABA Health Law Section Emerging Issues in Healthcare Law Bill Mathias 410.347.7667 wtmathias@ober.com Lisa Ohrin 410.786.8852 Lisa.Ohrin1@cms.hhs.gov February 28,
More informationRE: 340B Civil Monetary Penalties for Manufacturers and Ceiling Price Regulations (RIN AA89)
Office of Pharmacy Affairs Healthcare Systems Bureau Health Resources and Services Administration 5600 Fishers Lane Mail Stop 08W05A Rockville, MD 20857 Submitted via www.regulations.gov RE: 340B Civil
More informationHELAINE GREGORY, ESQ.
HCCA Puerto Rico Regional Annual Conference May 3, 2013 MODERATOR HELAINE GREGORY, ESQ. HCCA CONFERENCE CO-CHAIR PANEL DOROTHY DEANGELIS FTI CONSULTING MAITE MORALES MARTINEZ, ESQ., LL.M. MEDICAL CARD
More informationCMS Voluntary Self-Referral Disclosure Protocol: Latest Developments
Presenting a live 90-minute webinar with interactive Q&A CMS Voluntary Self-Referral Disclosure Protocol: Latest Developments Evaluating If, When and How to Report Potential Noncompliance With the Stark
More information340B Drug Pricing Program Ceiling Price and Manufacturer Civil Monetary Penalties. AGENCY: Health Resources and Services Administration, HHS.
This document is scheduled to be published in the Federal Register on 06/05/2018 and available online at https://federalregister.gov/d/2018-12103, and on FDsys.gov Billing Code: 4165-15 DEPARTMENT OF HEALTH
More informationStark Self-Disclosure 1/ Thomas S. Crane 2/ Mintz Levin Cohn Ferris Glovsky and Popeo, PC
SESSION Z Stark Self-Disclosure 1/ Thomas S. Crane 2/ Mintz Levin Cohn Ferris Glovsky and Popeo, PC A. Background 1. Stark Law The Physician Self-Referral Statute (or the Stark Law ) prohibits a physician
More informationANCILLARY services: How to Stay Out of Trouble. The neurosurgical minefield Informed consent
ANCILLARY services: How to Stay Out of Trouble Richard N.W. Wohns, M.D. JD, MBA NeoSpine, Puget Sound Region, Washington The neurosurgical minefield 2013 Informed consent HIPAA ARRA and HITECH Anti-Kickback
More informationAHLA. F. Anti-Kickback Primer. David E. Matyas Epstein Becker & Green PC Washington, DC
AHLA F. Anti-Kickback Primer David E. Matyas Epstein Becker & Green PC Washington, DC Martha J. Talley Chief, Industry Guidance Branch Office of the Inspector General US Department of Health and Human
More informationHealthcare Regulatory Issues We Wish We d Never Heard of
Healthcare Regulatory Issues We Wish We d Never Heard of Robert G. Homchick, Davis Wright Tremaine, LLP William W. Horton, Johnston Barton Proctor & Rose LLP #1 Will Tuomey Happen to Me? The problem: We
More information2012 Health Law Education Program: Anatomy of a Self- Disclosure Telling CMS About Your Stark Law Problems
2012 Health Law Education Program: Anatomy of a Self- Disclosure Telling CMS About Your Stark Law Problems October 24, 2012 12:00 p.m. 1:00 p.m. Central Web Seminar Continuing Education Information We
More informationBeneficiary Inducements
1 Beneficiary Inducements Heidi A. Sorensen HCCA South Central Regional Annual Conference November 12, 2010 Attorney Advertising Prior results do not guarantee a similar outcome Models used are not clients
More informationPACE & Medicare Part D
PACE & Medicare Part D www.npaonline.org Shawn Bloom National PACE Association Shawnb@npaonline.org (703) 535-1518 PACE & Part D Session Objectives PACE Medication Regulations What Does Part D Cover What
More informationSender's Direct Phone (202) Sender's Direct Facsimile (202) MEMORANDUM
PHILIP C. OLSSON RICHARD L. FRANK DAVID F. WEEDA (1948-2001) DENNIS R. JOHNSON ARTHUR Y. TSIEN JOHN W. BODE* STEPHEN D. TERMAN MARSHALL L. MATZ MICHAEL J. O'FLAHERTY DAVID L. DURKIN NEIL F. O'FLAHERTY
More informationMar. 31, 2011 (202) Federal agencies address legal issues regarding Accountable Care Organizations
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Room 352-G 200 Independence Avenue, SW Washington, DC 20201 Office of Media Affairs MEDICARE FACT SHEET FOR IMMEDIATE RELEASE
More informationMEDICARE PLAN PAYMENT GROUP
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, Maryland 21244-1850 MEDICARE PLAN PAYMENT GROUP Date: May 30, 2018 To: From: All Part D
More informationStaying Compliant: A Roadmap to Self-Disclosure
12/18/2015 Staying Compliant: A Roadmap to Self-Disclosure By Linda A. Baumann and Hillary Stemple, Arent Fox LLP The new requirements for overpayment return, along with increasing enforcement, are making
More informationH e a l t h C a r e Compliance Adviser
March 2001 Volume 5 Number 1 H e a l t h C a r e Compliance Adviser OIG Issues New Advisory Opinion on Gainsharing Reversing July 1999 Special Advisory Bulletin In a welcome departure from its former position,
More informationCMS Unveils 12-Step Reconciliation Process For Retiree Drug Subsidy (RDS)
CMS Unveils 12-Step Reconciliation Process For Retiree Drug Subsidy (RDS) The Centers for Medicare and Medicaid Services (CMS) has announced a 12-step final reconciliation process for plan sponsors receiving
More informationAuditing RACphobia. Lamon Willis, CPCO, CPC-I, CPC-H, CPC AHIMA-Approved ICD-10-CM/PCS Trainer Xerox Healthcare Consultant
Auditing RACphobia Lamon Willis, CPCO, CPC-I, CPC-H, CPC AHIMA-Approved ICD-10-CM/PCS Trainer Xerox Healthcare Consultant 1 Agenda Overview of present industry landscape in relation to auditing Audit Entities
More informationTRACKING MEDICARE HEALTH AND PRESCRIPTION DRUG PLANS Monthly Report for October 2007
TRACKING MEDICARE HEALTH AND PRESCRIPTION DRUG PLANS Monthly Report for October 2007 Prepared by Stephanie Peterson and Marsha Gold, Mathematica Policy Research Inc. as part of work commissioned by the
More informationMAY 11, 2016 CMS Resets the Clock for Return Of Medicare Overpayments
PRN MAY 11, 2016 CMS Resets the Clock for Return Of Medicare Overpayments Mark F. Weiss, JD Finders keepers, losers weepers. Except in connection with overpayments from Medicare, then it s a violation
More informationJanuary 16, Seema Verma Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244
Seema Verma Administrator Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244 RE: CMS-4182-P: Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare
More informationFraud, Waste and Abuse A Presentation for Network Providers
Fraud, Waste and Abuse A Presentation for Network Providers Presentation Topics TOPICS SLIDES Our Pledge 1 The Law 4-8 Definitions 9-12 Waste and Recovery 14-18 Recipient Fraud 19-25 Provider Fraud 26-28
More informationRules of the Road in Investigating and Disclosing Overpayments. Jesse A. Witten Drinker Biddle & Reath LLP
Rules of the Road in Investigating and Disclosing Overpayments Jesse A. Witten Drinker Biddle & Reath LLP I. Legal Authorities Regarding Disclosure of Overpayments A. 60-Day Rule : 1. Affordable Care Act
More informationSubmitted via Federal e-rule making Portal: April 5, 2019
1 Submitted via Federal e-rule making Portal: http://www.regulations.gov April 5, 2019 Aaron Zajic Office of Inspector General Department of Health and Human Services Cohen Building, Rm 5527 330 Independence
More informationTransparency, Reporting & Data Mining
Transparency, Reporting & Data Mining Kimberly Brandt, CHC, JD Alston & Bird, LLP Shawn DeGroot, CHC-F, CCEP, CHRC Vice President of Corporate Responsibility Regional Health Size and Scope of Data 2 1
More informationRISE RAPS-EDS Collaboration Research Project Executive Summary
RISE RAPS-EDS Collaboration Research Project Executive Summary Christie Teigland, Ph.D. 1.26.17 Avalere Health T 202.207.1300 avalere.com An Inovalon Company F 202.467.4455 1350 Connecticut Ave, NW Washington,
More informationGETTING SERIOUS ABOUT MEDICAID COMPLIANCE:SECTION 6402 OF PPACA AND THE DUTY OF DISCLOSURE OF IDENTIFIED OVERPAYMENTS 7/14/10
GETTING SERIOUS ABOUT MEDICAID COMPLIANCE:SECTION 6402 OF PPACA AND THE DUTY OF DISCLOSURE OF IDENTIFIED OVERPAYMENTS 7/14/10 JAMES G. SHEEHAN NEW YORK MEDICAID INSPECTOR GENERAL James.Sheehan@OMIG.NY.GOV
More informationMedicare Program Integrity: Overview and Issues
Medicare Program Integrity: Overview and Issues Marjorie Kanof, M.D. Managing Director, Health Care U.S. Government Accountability Office February 22, 2007 1 Overview Introduction to Medicare What is Program
More informationStark/Anti- Kickback Fundamentals
Stark/Anti- Kickback Fundamentals HEALTHCON Business Expo April 2016 Presented by: Stacy Harper, JD, MHSA, CPC 1 Disclaimer This presentation is for general education purposes only. The information contained
More informationMedical Ethics. Paul W. Kim, JD, MPH O B E R K A L E R
Medical Ethics Paul W. Kim, JD, MPH O B E R K A L E R 410-347-7344 pwkim@ober.com 1 Agenda Federal Fraud & Abuse Laws Federal Privacy Laws Enrollment Audits Post-Payment Audits Pre-Payment Reviews 2 False
More informationFraud, Waste and Abuse
Fraud, Waste and Abuse A Presentation for Network Providers Presented by: Pennsylvania and Northeast Presentation Topics TOPICS SLIDES Our Pledge 1 The Law 4-8 Definitions 9-12 Waste and Recovery 14-18
More informationRetiree Drug Subsidy Update and RDS Program Oversight
Retiree Drug Subsidy Update and RDS Program Oversight Center for Beneficiary Choices (October 2005) Introduction Today s discussion Refresher on Employer Options Update on RDS Program Retiree Drug Subsidy
More information60-Day Overpayment FCA Enforcement Action Results in $2.95 Million Settlement Kin...
Page 1 of 6 60-Day Overpayment FCA Enforcement Action Results in $2.95 Million Settlement 8/30/2016 by Stephanie Johnson King & Spalding Like 0 0 Tweet Share On August 23, 2016, a New York hospital system
More informationNavigating Self-Disclosure
Navigating Self-Disclosure Charlie Fletcher, CHC Chief Compliance Officer MAURY REGIONAL MEDICAL CENTER Matthew M. Curley BASS BERRY & SIMS PLC John N. Joseph POST & SCHELL, P.C. Self-Disclosure: Legal
More informationSession 108 L, Medicare Advantage MLR: Year Two. Moderator/Presenter: Scott O Neil Jones, FSA, MAAA
Session 108 L, Medicare Advantage MLR: Year Two Moderator/Presenter: Scott O Neil Jones, FSA, MAAA SOA Antitrust Disclaimer SOA Presentation Disclaimer Medicare Advantage MLR: Year Two 2016 SOA Annual
More informationBuilding Clinical Trial Revenue Integrity Compliance Through Auditing and Understanding Payer Requirements
Building Clinical Trial Revenue Integrity Compliance Through Auditing and Understanding Payer Requirements Kelly Willenberg, DBA, RN, CHRC, CHC, CCRP Kelly Willenberg & Associates Wendy S. Portier, MSN,
More informationThe Sunshine Act: Where it stands, where it s going and compliance implementation
The Sunshine Act: Where it stands, where it s going and compliance implementation PRESENTED BY: Stacey A. Filice Jazz Pharmaceuticals Disclaimer slide The views expressed in this presentation are my own
More informationFederal Register / Vol. 70, No. 195 / Tuesday, October 11, 2005 / Proposed Rules
59015 (2) Determining medical improvement and its relationship to your abilities to do work. * * * (In addition, see paragraph (b)(8) of this section if you work during your current period of eligibility
More informationHandling Potential Overpayment and "Voluntary" Refund Situations
Handling Potential Overpayment and "Voluntary" Refund Situations Timothy P. Blanchard, MHA, JD American Academy of Professional Coders 2011 National Conference April 4, 2011 2011 Blanchard Manning LLP.
More informationCompliance Risk Areas for Health Centers: A Financial Perspective. Marcie H. Zakheim Partner
Compliance Risk Areas for Health Centers: A Financial Perspective Marcie H. Zakheim Partner DISCLAIMER This training has been prepared by the attorneys of Feldesman Tucker Leifer Fidell LLP. The opinions
More informationStark and the Anti Kickback Statute. Regulating Referral Relationship. February 27-28, HCCA Board Audit Committee Compliance Conference.
Stark and the Anti Kickback Statute Ryan Meade, JD, CHRC, CHC F Director, Regulatory Compliance Studies Beazley Institute for Health Law and Policy Loyola University Chicago School of Law rmeade@luc.edu
More informationH.R. 938 Enhancing Medicaid TPL
H.R. 938 Enhancing Medicaid TPL Michele Carpenter, SVP Government Services Kristen Ballantine, VP Government Relations May 25, 2017 1. About HMS Agenda 2. Third Party Liability (TPL) History Legal authority
More informationDown the Rabbit Hole: Compliance Investigations, Corrective Action Planning, and Self-Disclosure
Health Care Compliance Association 2017 Annual Healthcare Enforcement Compliance Institute Down the Rabbit Hole: Compliance Investigations, Corrective Action Planning, and Self-Disclosure Anne Sullivan
More informationRegulations.gov Monday, December 10, 2007 Unified Agenda
PENSION BENEFIT GUARANTY CORPORATION 29 CFR Ch. XL Agenda of Regulations Under Development AGENCY: (PBGC). ACTION: Semiannual regulatory agenda. SUMMARY: This document sets forth the 's regulatory agenda
More informationLinking Performance and Compliance: How Part D Quality Measures Relate to Plan Performance
Linking Performance and Compliance: How Part D Quality Measures Relate to Plan Performance Medicare Rx Part D Compliance Conf. Monday, December 8, 2008 9:45 a.m. 10:45 a.m. Cynthia Tudor, PhD Director
More informationAnticipating Medicare's Alphabet Soup of Audit Contractors, Ranging from ZPICs and RACs to CERTs and MACs
Anticipating Medicare's Alphabet Soup of Audit Contractors, Ranging from ZPICs and RACs to CERTs and MACs 18th Annual Executive War College April 30-May 1, 2013 New Orleans, LA Presented by: Christopher
More informationSession 98 L, Medicare Advantage Risk Adjustment: Past, Present and Future. Presenters: Adrian L. Clark, FSA, MAAA David Benjamin Koenig, FSA, MAAA
Session 98 L, Medicare Advantage Risk Adjustment: Past, Present and Future Presenters: Adrian L. Clark, FSA, MAAA David Benjamin Koenig, FSA, MAAA SOA Antitrust Disclaimer SOA Presentation Disclaimer Medicare
More informationPart D Performance Audits - Formulary Administration
Part D Performance Audits - Formulary Administration February 13, 2012 Medicare Drug Benefit and C&D Data Group Centers for Medicare & Medicaid Services Judith Geisler, R.Ph., CHC Formulary Administration
More informationFINANCIAL DISCLOSURES AND CONFLICTS OF INTEREST IN CLINICAL RESEARCH
FINANCIAL DISCLOSURES AND CONFLICTS OF INTEREST IN CLINICAL RESEARCH Richard S Liner, JD Ronald H. Clark, PhD, JD Arent Fox Kintner Plotkin & Kahn, PLLC Washington D.C./New York 1 In light of the expansion
More informationAnti-Kickback Statute and False Claims Act Enforcement
Anti-Kickback Statute and False Claims Act Enforcement Nicholas Gachassin, III, Esq. Gachassin Law Firm, LLC Nick3@gachassin.com Press Conference on Health Care Fraud and the Affordable Care Act May 13,
More informationPolicy Proposals for Reducing Health Care Costs. Marc Boutin, JD Chief Executive Officer
Policy Proposals for Reducing Health Care Costs Marc Boutin, JD Chief Executive Officer April 25, 2017 Project Goal and Approach Develop policy recommendations from the patient perspective about health
More informationLeah Guidry, Managing Director, Huron Consulting Group Lisa Ohrin, Esq., Partner, Katten Muchin Rosenman
Health Care Compliance Association: 2011 Compliance Institute Physician Vendor Relationships: Operationalizing Compliance with the Stark Anti-kickback Laws Leah Guidry, Managing Director, Huron Consulting
More informationOIG and CMS Voluntary Self Disclosures: Weighing the Risks and Rewards of Self Reporting
Presenting a live 90-minute webinar with interactive Q&A OIG and CMS Voluntary Self Disclosures: Weighing the Risks and Rewards of Self Reporting Leveraging Tools for Resolving Stark Law or Anti-Kickback
More informationMedicare Advantage (MA) Benefit Design and Beneficiary Choice
Medicare Advantage (MA) Benefit Design and Beneficiary Choice June 29, 2009 AcademyHealth Annual Research Meeting, Chicago, Illinois Marsha Gold, Sc.D. Senior Fellow Research Questions and Topics Covered
More informationContinuation of the Prescription Drug Event (PDE) Reports and PDE Analysis Reporting Initiatives for the 2014 Benefit Year
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Center for Medicare 7500 Security Boulevard Baltimore, Maryland 21244-1850 Center for Medicare Medicare Plan Payment Group
More informationRecovery Audit Contractors The Beginning to Now and Overview RACs Challenged by Providers? A Recent OIG Report May Be Indicating Just That 1 CEU
Recovery Audit Contractors The Beginning to Now and Overview RACs Challenged by Providers? A Recent OIG Report May Be Indicating Just That 1 CEU Article submitted by Carl James Byron, III ATC-L, CHA CPC,
More informationSpecialty Pharmacies. Ensuring Compliant Relationships. April 2017
Specialty Pharmacies Ensuring Compliant Relationships April 2017 Agenda I. Current climate II. Regulatory Overview III. Types of SPP relationships IV. Data purchase arrangements V. Fee for service arrangements
More informationContracting With Research Sites And Investigators: A Fraud And Abuse Primer
Epstein Becker & Green, P.C. Contracting With Research Sites And Investigators: A Fraud And Abuse Primer Presented by: Elizabeth A. Lewis www.ebglaw.com Checklist for Compliance: Contracting Guidelines
More informationA DISCUSSION WITH THE OIG
1 A DISCUSSION WITH THE OIG MICHAEL J ARMSTRONG REGIONAL INSPECTOR GENERAL FOR AUDIT SERVICES STEPHEN J CONWAY DIRECTOR, ADVANCED AUDIT TECHNIQUES ROBERT K DECONTI CHIEF, ADMINISTRATIVE & CIVIL REMEDIES
More informationCompliance Program. Health First Health Plans Medicare Parts C & D Training
Compliance Program Health First Health Plans Medicare Parts C & D Training Compliance Training Objectives Meeting regulatory requirements Defining an effective compliance program Communicating the obligation
More information7/25/2018. Government Enforcement in the Clinical Laboratory Space. The Statutes & Regulations. The Stark Law. The Stark Law.
Government Enforcement in the Clinical Laboratory Space 2 SCOTT R. GRUBMAN, ESQ. The Statutes & Regulations 3 4 AKA the physician self-referral law The Rule: If physician (or immediate family member) has
More informationRegulatory Compliance Policy No. COMP-RCC 4.21 Title:
I. SCOPE: Regulatory Compliance Policy No. COMP-RCC 4.21 Page: 1 of 6 This policy applies to (1) Tenet Healthcare Corporation and its wholly-owned subsidiaries and affiliates (each, an Affiliate ); (2)
More informationDisclaimer. The materials and views expressed in this presentation are the views of the presenters and not necessarily the views of Northwell Health
Helpful Tips for Value Based Payment (VBP) Compliance Programs Greg Radinsky Vice President & Chief Corporate Compliance Officer Aaron Lund Director of Corporate Compliance & Privacy Officer Disclaimer
More information