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Summary of the US Department of Health & Human Services Office of Inspector General Semiannual Report to Congress October 2012—March 2013

June 5, 2013


Every six months the Department of Health and Human Services (HHS) Office of Inspector General (OIG) Semiannual Report to Congress describes significant problems, abuses, deficiencies, and investigative outcomes undertaken by the Department. The Semiannual Report is often described as the OIG's “make good report” to support ongoing investigations and additional funding requests to Congress. This report provides some valuable insight to all health care providers on the war against fraud and abuse.


Advancements in Military Medical Care Help All of Us: Recognizing and Reimbursing New Treatments and Technology

May 29, 2013

Memorial Day was first widely observed in May 1868, to commemorate the sacrifices of the Civil War, when family members and citizens across the United States decorated the graves of more than 20,000 Union and Confederate soldiers. MiraMed Global Services (MMGS) would like to take a moment to thank all veterans and their families for the sacrifices they have made for our freedom.


CMS Instructions for Healthcare Providers and Facilities in the Event of a Disaster or an Emergency Situation

May 22, 2013


Natural disasters in America are always difficult. Our first concern is about the safety and welfare of the people involved. The buildings, the cars that are tossed around like toys and the personal belongings, while precious to their owners, quickly become meaningless when life and limbs are at risk. MiraMed Global Services' (MMGS) prayers are with the victims of the Moore, Oklahoma tornado this past Monday. Catastrophic events like the recent tornado, Hurricane Sandy, and flooding throughout the plains area a few months ago, make us all appreciate what is most important to us.


SPECIAL ALERT: Healthcare Providers Can File Claims for Repayment under MasterCard and Visa Class Action Settlement

May 15, 2013

Jackson, MI, May 15, 2013– MiraMed Global Services, Inc. (MiraMed) has announced Healthcare providers that accept Visa and MasterCard payments are among the “merchants” that may be able to collect a portion of the fees paid to the card issuers under the proposed settlement in the Payment Card Interchange Fee and Merchant Discount Antitrust Litigation pending in federal District Court in New York.


Office of Inspector General (OIG): Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs

May 15, 2013

On May 8, 2013, the OIG released an updated 20-page Special Advisory Bulletin describing the scope and effect of the legal prohibition on payment by Federal health care programs for items or services furnished (1) by an excluded person or (2) at the medical direction or on the prescription of an excluded person. The updated Bulletin provides guidance to the health care industry on the scope and frequency of screening employees and contractors to determine whether they are excluded persons.


Eight Things Hospitals Must Know About the CMS 2014 Proposed IPPS

May 8, 2013

On April 26, the Centers for Medicare and Medicaid Services (CMS) released its display copy of the proposed 2014 Inpatient Prospective Payment System (IPPS) for acute care hospitals (Proposed Rule). The Proposed Rule will be published in the Federal Register on May 10. The following include some notable provisions of the Proposed Rule:


IRS: Meaningful Use Incentive Payments are Taxable Income

May 1, 2013

In a memorandum dated January 14, 2013, the Office of Chief Counsel (Office) of the Internal Revenue Service (IRS) took the position that recipients of incentive payments for meaningfully using electronic health records (EHRs) under the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Programs (Programs) must claim such incentive payments as income for tax purposes. In its memorandum, the Office considered the following three issues:


OIG Self-Disclosure Protocol – To Disclose or Not to Disclose

April 24, 2013

In an enforcement environment such as the one in which we experience today, wherein the government gains roughly $7 for every $1 it puts into enforcement, healthcare providers and suppliers regularly find themselves faced with new and increasing compliance enforcement threats. A provider or supplier’s failure to comply with the healthcare laws and regulations could be brought to the OIG’s attention in a number of ways, including:


CMS and OIG Revisit EHR Software Exception and Safe Harbor

April 17, 2013

On April 10, the Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) both issued proposed rules regarding arrangements involving electronic health records (EHRs) under the physician self-referral statute (Stark Law) and the Anti-Kickback Statute (AKS). Both the Stark Law and AKS currently have exceptions for certain arrangements involving the provision of EHR software to physicians in a position to refer patients back to the facility and are facing proposed changes.


The National Commission on Physician Payment Reform

April 10, 2013

For the last 15 years, the physician payment policy that has been closest to home for practicing physicians has involved repeated down-to-the-wire congressional interventions to avert large Medicare payment rate cuts specified by the sustainable growth rate (SGR) formula. Less visible, but potentially as important or more important over the longer term, has been a series of steps to revamp the resource-based relative value scale (RBRVS) which is the foundation of the Medicare Physician Fee Schedule (MPFS), with the goal of more accurately reflecting the relative costs of providing different physician services. The 2010 Patient Protection and Affordable Care Act (ACA) authorized initiatives to explore broader payment reforms such as accountable care organizations and bundled payments. Although the focus of physician-payment policy has been the Medicare program, the impact is much broader, since private insurers and Medicaid programs incorporate many of the Medicare changes into their systems of payment to physicians.


Questions and Answers Regarding the 2% Medicare Payment Cut and How it Will Impact Healthcare Providers

April 4, 2013

MiraMed Global Services (MMGS) is receiving some very good questions from our clients regarding more details on how the sequestration 2% Medicare payment cut will impact their reimbursement. We are continuing to monitor CMS and Medicare carriers’ websites, including Palmetto, CGS, Novitas, First Coast Service Options and NHIC.


Enforcement Discretion Ending for Insurers to Support HIPAA Transactions for Patient Insurance Eligibility Verification and Claim Status

April 3, 2013

The discretionary enforcement period, instituted by the Centers for Medicare & Medicaid Services (CMS) on January 1, is scheduled to end March 31 for operating rules that support the HIPAA transactions for patient insurance eligibility verification and claim status. Although the Affordable Care Act (ACA) required health plans and others to comply by the first of this year, CMS decided it would not initiate enforcement action until April 1. After March 31, health plans will be required to comply with a series of business rules, making it possible for practices to identify, for example, patient co-pays and remaining deductibles within 20 seconds of sending the electronic request to the health plan.


OIG Turns its Attention to Physician-Owned Distributorships

March 27, 2013

In its first new Special Fraud Alert in the past decade, the Office of Inspector General (OIG) focused its attention on physician-owned entities deriving revenue from selling, or arranging for the sale of, implantable medical devices ordered by their physician-owners, commonly known as physician-owned distributorships or PODs.  The issue of whether PODs are permissible under the Federal fraud and abuse laws has been an issue of debate as of late.  In fact, in light of the controversy, in 2011, the Senate Finance Committee issued letters to the OIG that insisted the two bodies to take a position and issue guidance on PODs and how they fit within the current legal structure governing healthcare transactions and relationships.  The Special Fraud Alert: Physician-Owned Entities (Alert) appears to be a response to the 2011 letter to the OIG.


CMS’s New Part B Rebilling Rule and its Impact on Hospitals

March 20, 2013

Typically, when a patient presents at a hospital in need of care, the physician (or other qualified practitioner) may either admit the patient for inpatient care or treat the patient as an outpatient.  Oftentimes, when the patients are admitted as an inpatient, an audit conducted by Medicare auditors and contractors (e.g., Medicare Administrative Contractors (MACs), Recovery Auditors (RAs) or Comprehensive Error Rate Testing (CERT) Contractors) results in denial of the Part A claims as not being reasonable and necessary.  Currently, hospitals may bill a subsequent Part B inpatient claim for a limited set of medical and other health services, commonly referred to as “Part B inpatient” or “Part B  only” services, even if additional services furnished would have been medically necessary had the beneficiary been treated as an outpatient.  The American Hospital Association, alongside Missouri Baptist Sullivan Hospital, Munson Medical Center, Lancaster General Hospital and Trinity Health Corporation filed a law suit in November of last year regarding this issue of denials for Part A claims.  


Strategies for Reducing Hospital Readmissions

March 13, 2013

The issue of reducing hospital readmissions has been one that hospitals and physicians have faced for years.  However, with the passing of the Patient Protection and Affordable Care Act (PPACA), the issue has become much more personal.  Now, hospitals with higher-than-expected readmission rates must be penalized. 

The issue of reducing hospital readmissions has been one that hospitals and physicians have faced for years.  However, with the passing of the Patient Protection and Affordable Care Act (PPACA), the issue has become much more personal.  Now, hospitals with higher-than-expected readmission rates must be penalized. 


Are Your Computer and Mobile Networks Secure Enough for Today’s Healthcare Environment?

March 6, 2013

While much of the healthcare world has been focused on the Health Insurance Portability and Accountability Act of 1996 (HIPAA), especially with the release of the new omnibus rule, it is not without good reason.  In a recent publication in the New England Journal of Medicine, Protecting Patient Privacy and Data Security, Julie K. Taitsman, MD, JD, Christi Macrina Grimm, MPA and Shantanu Agrawal, MD—all of who work for the Office of Inspector General (OIG)—state that the issue of privacy and security of patient information is still at the forefront of the government’s focus.


The Countdown to Sequester and the Impact on Healthcare

February 27, 2013

This Friday, March 1, marks the day in which across-the-board spending cuts (to the tune of $85 billion) take effect.  Regardless of one’s political position and opinion, it is undeniable that the impact on the healthcare industry will be great. This alert summarizes some of the anticipated affects the sequester will have on the industry.


CMS Sunshine Act Regulations Released: Is The Grass Always Greener Where the Sun Shines?

February 20, 2013

Section 6002 of the Affordable Care Act (ACA) requires certain applicable manufacturers of drugs, devices, biological or medical supplies to annually report to the Secretary of Health and Human Services (Secretary) certain payments or other transfers of value to physicians and teaching hospitals.  Moreover, applicable group purchasing organizations (GPOs) must disclose any ownership or investment interests in such entities held by physicians or their immediate family members as well as information on payments or other transfers of value to such physician owners or investors.  This law is commonly referred to as the “Sunshine Act”. 


CMS Proposes to Clean Up its Regulations

February 13, 2013

Yes, you read that correctly.  The Centers for Medicare and Medicaid Services (CMS) has identified certain regulations as unnecessary, obsolete, or excessively burdensome and proposes to “increase the ability of health care professionals to devote resources to improving patient care, by implementing or reducing requirements that impede quality patient care or that divert resources away from providing high quality patient care.”  CMS’s proposals are set forth in a proposed rule that was published in the Federal Register on February 7 (Proposed Rule).


CMS Announces Groups Participating in Bundled Payments Initiative

February 6, 2013

On January 31, 2013, the Centers for Medicare and Medicaid Services (CMS) announced the healthcare organizations it selected to participate in the Bundled Payments for Care Improvement Initiative (Initiative). The Initiative will test how bundling payments for certain episodes of care can result in increased coordination of care for beneficiaries and decreased cost to Medicare. According to CMS, the Initiative intends to achieve the following:


Disclosures of Protected Health Information in Light of Recent Tragedies

January 30, 2013

In light of the recent Office of Civil Rights (OCR) Health Insurance Portability and Accountability Act of 1996 (HIPAA) final rule that was recently released, many healthcare providers and suppliers have been put on the defensive when it comes to the use or disclosure of protected health information (PHI), especially because of the increased penalties for violating the rules. Moreover, considering the recent tragedies that have shocked our country, including the shootings at Newtown, CT and Aurora, CO, the issue of disclosures of PHI to protect against such tragedies has been raised. On January 15, the OCR issued a message to healthcare providers reminding them that the Privacy Rule does not prevent a covered entity’s ability to disclose necessary information about a patient to law enforcement, family members of the patient or other persons when there is a belief that the patient presents a serious danger to him/herself or other people.


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