Posts Tagged: medical fraud

CMS Modifies The FFS Medical Review Process for FY2010

The vast majority of Medicaid errors are due to inadequate documentation…” – CMS

The above statement comes directly from a Fact Sheet just posted on the CMS website. (Find the sheet here.) Candidly, we know this is not really NEW. It is a rather aged refrain. Nevertheless, we think it stands reporting/repeating, because it does seem to keep coming up, and this is just the latest, most public declaration of what is really at issue, and further substantiates what was even reported during the RAC Demonstration Project.

What is “news” is this statement in the Fact Sheet:

Based on recommendations from the HHS Office of the Inspector General (OIG), Members of Congress and CMS clinical experts, the Agency modified the FFS medical review process used to identify improper payments this year.

There is no explanation of what or how they changed the review process, but the results are quite impressive:

As a result of this heightened scrutiny and more complete accounting of Medicare FFS claims, CMS is reporting a 2009 FFS error rate of 7.8 percent, or $24.1 billion, compared to 3.6 percent in 2008.

The calculated error rate more than doubled, between 2008 and 2009. One can readily deduce that the changes, whatever they are, are significant.

The changes are neither listed nor detailed, but CMS does state that it is “taking further steps” to insure the following:

  • that providers are submitting all required clinical and medical documents to support a claim,
  • that providers’ signatures on medical documents are legible,
  • that a provider’s claims history can no longer be used to fill in missing treatment documentation, and
  • will require that medical information from a provider be included to support DME claims, in addition to the already required records from suppliers.

All of those steps are significant. While CMS again neither mentions nor details what these “further steps” are, it behooves a provider to pay attention to what they have outlined as their intended targets — namely, the four bullets, above.

It is also interesting to note that while much of the industry is focused on what the RACs are doing, the RACs were not even mentioned in this report, but HEAT was directly named. If you are not aware of HEAT, you should see our previous post about them.

See our news article about CMS’ Press Release and the Fact Sheet, here.

RAC Defense

Maybe you’ve already thought about this, but there’s lots to learn… so we’ll keep making suggestions…

RAC defense will include many of the areas we all deal  with day-in and day-out, and a few which may be new to you — such as development and implementation of a Hospital wide Case Management Protocol.

Oh. Never heard of it…………..??  Read on…

Atlanta based, St. Joseph’s Hospital reached agreement with the DOJ and OIG (for a mere $26 Million) on issues relating to patient admission status (Observation vs Inpatient) and included in their CIA is the requirement to adopt a Case Management Protocol. To see what is involved go to www.myedutrax.com, Register (it’s free, takes a minute), then search for “St. Joseph’s”.

Wisest course is to consider such a step for development and implementation before it is “too late”.

More details to come…

$12K Average Take Back

Ok, so does THAT number get your attention?  It’s a real number.

The so-called “demonstration project” run by CMS from October 2006 thru March 2008 only operated in three states: New York, California and Florida. One of the three RAC contractors in the project reported an average take back per claim of $12,157 for inpatient claims at audited Hospitals, Inpatient Rehab Facilities and SNFs. Also, they reported that the average total take backs per facility was $483,774 at those facilities.

More details are available on our site at www.myedutrax.com

In a coming post, we’ll look at more detail in the single most costly take back found in the above facilities.

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