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Regulatory MonitoringAuthor Archive
Other Issuances: OIG audits Epogen, oxaliplatin, Region B RAC updates issues, and more
CGI updates approved audit issues
CGI Federal, the RAC for Region B, has posted an updated list of approved audit issues.
OIG audits Epogen payments
On October 8, the OIG issued two audit reports on payments for Epogen administration at University of Virginia Medical Center–Lynchburg Dialysis and Bon Secours Baltimore Hospital Renal Dialysis Center. The OIG found that the facilities did not meet Medicare payment requirements for some dates of service and that policies and procedures were not always followed.
OIG audits oxaliplatin payments
On October 7, the OIG issued an audit report of payments for oxaliplatin administration made during 2005 by National Government Services (NGS), a Medicare fiscal intermediary for West Virginia. The OIG determined that NGS made overpayments totaling $433,000 for oxaliplatin drug services.
CMS posts new RAC FAQ
Will Code N432 appear on the remittance advice for Recovery Audit Contractor (RAC) adjusted claims?
Editor’s note: Judith Kares, JD, CPC, regulatory specialist for HCPro, Inc., is the author of this week’s note from the instructor.
Now that CMS has implemented a permanent and nationwide Recovery Audit Contractor (RAC) Program, as authorized by the Tax Relief and Healthcare Act of 2006, hospitals need to keep themselves informed about the issues that have been approved for review in their region. Going forward, the four regional RACs will continue to review claims on a post-payment basis, using standard Medicare policies. They will be limited, however, to a three-year look-back period, with no review of claims paid prior to October 1, 2007.
Editor’s note: Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc., is the author of this week’s note from the instructor.
In last week’s note, we looked at the OIG Work Plan for Fiscal Year 2010. There were many issues listed for both Part A and Part B that will be on the radar for a targeted review. Hospitals are encouraged to closely examine the OIG Work Plan as part of their annual compliance program review process.
In addition, reviewing OIG audits can help hospitals and physicians identify some challenging areas within their own operations. This week, CMS published Transmittal 574 that focused on four recent OIG reports:
- Part B Chemotherapy Administration Payment and Policy;
- Prevalence and Qualifications of Nonphysicians Who Perform Medicare Physician Services;
- Inappropriate Medicare Payments for Chiropractic Services; and,
- Part B Billing for Ultrasound.
OIG issues review of CERT program
On September 29, the OIG issued an audit report on the Comprehensive Error Rate Testing (CERT) program.
HDI updates approved audit issues
HealthDataInsights (HDI), the region D RAC, has updated its list of approved audit issues.
Frequently asked questions
CMS posted several new/updated frequently asked questions (FAQ).
CMS strengthens program safeguards
On October 9, CMS issued a transmittal referencing several OIG reports that highlighted Medicare’s vulnerability to questionable claims. CMS instructed contractors to review claims data, especially for those services audited by the OIG.
Effective date: November 9, 2009
Implementation date: November 9, 2009
CMS rescinds and replaces “Pickle Amendment” transmittal
On October 9, CMS rescinded and replaced a previous transmittal regarding the status verification of all hospitals receiving disproportionate share hospital, or DSH, payments under 42 CFR Section 412.106(c)(2), also known as the "Pickle Amendment."
Effective date: October 5, 2009
Implementation date: October 5, 2009
MLN Matters articles
CMS released a special edition MLN Matters article.
CMS also released an MLN Matters article related to a transmittal previously outlined in Medicare Weekly Update.
CMS issues IPPS correction
On October 7, CMS issued a correction in the Federal Register to its previously issued IPPS final rule for 2010.
OCR publishes HIPAA proposed rule in Federal Register
On October 7, the Office for Civil Rights (OCR) published in the Federal Register a proposed rule that would strengthen privacy protections for genetic information, as required by the Genetic Information Nondiscrimination Act of 2008. The OCR had previously issued the proposal in display copy.
The next Hospital & Hospital Quality Open Door Forum (HODF) is scheduled for Thursday, October 8, at 2 p.m. Eastern. To participate, dial 800/837-1935 and reference conference ID 22148926.
Transcripts and audio of the HODF call will be available to MedicareFind users approximately one week after the call.
CMS issues annual flu vaccine payment allowance update
On October 2, CMS issued a transmittal to update the payment allowances for the influenza vaccine for the 2009-2010 season.
Effective date: September 1, 2009
Implementation date: November 2, 2009
CMS issues instructions on implementation of new RAC mass adjustment process
On October 2, CMS issued a transmittal to implement a new file-based RAC mass adjustment process in the VMS.
Effective date: April 5, 2010
Implementation date: April 5, 2010
CMS modifies RAC mass adjustment process in FISS
On October 2, CMS issued a transmittal to correct a problem with the file-based RAC mass adjustment process in FISS.
Effective date: April 5, 2010
Implementation date: Phase I will include analysis/design and will be completed by January 4, 2010; actual coding/testing will occur in Phase II with an implementation date of April 5, 2010.
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