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MEASURING COMPLIANCE PROGRAM EFFECTIVENESS

Measuring compliance program effectiveness is recommended by several authorities, including the United States Sentencing Commission (see, Chapter 8 of the United States Sentencing Guidelines). The Compliance Department is not permitted to perform these audits. Audits must be performed independently, to avoid self-policing. https://www.cms.gov/Medic...
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CONGRESS LIFTS MEDICARE THERAPY LIMITS

On February 9, 2018, Congress enacted a permanent solution to the hard cap on outpatient therapy services under Medicare Part B, ending a cycle of short-term fixes that have been necessary since its introduction in 1997 as part of the Balanced Budget Act. The legislation that has been enacted provides a fix for the therapy cap by permanently extend...
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MEDICARE REVISES E/M SERVICE DOCUMENTATION PROVIDED BY STUDENTS

On February 2, 2018, CMS issued Transmittal 3971 revising Pub. 100-04, Medicare Claims Processing Manual, Chapter 12, Section 100.1.1, B, that allows the teaching physician to verify in the medical record any student documentation of components of evaluation and management (E/M) services, rather than redocumenting the work. The policy change applie...
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ROBERT TRUSIAK DISCUSSES COMPLIANCE REQUIREMENTS AFTER ESCOBAR, RUCKH AND THE SET ASIDE OF $347M FALSE CLAIMS ACT JURY AWARD

My comments follow and generally address the legal and compliance considerations associated w/ the set aside of a jury verdict for $347M due to FCA violations determined by a jury related to the absence of nursing home care. These views were generally addressed in an interview by me appearing in the Report on Medicare Compliance, V. 27, #3, Jan. 22...
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SAMHSA ISSUES FINAL RULE UPDATING SUBSTANCE ABUSE CONFIDENTIALITY REGULATIONS

The Substance Abuse and Mental Health Services Administration (SAMHSA), part of the U.S. Department of Health and Human Services (HHS), has finalized proposed changes to the Confidentiality of Substance Use Disorder Patient Records regulation, 42 CFR Part 2, aimed at supporting payment and healthcare operations activities while protecting the confi...
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Medicare Compliance Journal

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