MIC, MAC & RAC – Oh My! 1 THE WORLD OF MEDICAL CLAIMS AUDITING HealthCare Management Consultants 2013 TRANSLATION, PLEASE 2 ACRONYM PROGRAM NAME MIC Medicaid Integrity Contractor MAC Medicare Administrative Contractor RAC Recovery Audit Contractor OREGON CONTRACTOR HMS Noridian Healthcare Solutions Health Data Insights OTHER AUDITING ENTITIES ZPIC Zone Program Integrity Contractor HealthCare Management Consultants 2013 NCI, Inc TRANSLATION, PLEASE 3 FEDERAL AGENCIES ACRONYM PROGRAM NAME DOJ Department of Justice OIG Office of Inspector General FBI Federal Bureau of Investigation HEAT Health Care Fraud Prevention & Enforcement Action Team OTHER MEDICAID AUDIT ENTITIES MEDICAID RAC Medicaid RAC MFCU Medicaid Fraud Control Unit MIP Medicaid Integrity Program OMIG State Office of Medicaid Inspector General HealthCare Management Consultants 2013 TRANSLATION, PLEASE 4 OTHER CMS AUDITS ACRONYM CERT PROGRAM NAME CONTRACTOR Comprehensive Error Rate Testing AdvanceMed/Livanta OTHER AUDITING ENTITIES Other local or national insurance carriers Also, your MAC or any other carrier can initiate an audit based on review of individual claims or whistleblower report HealthCare Management Consultants 2013 MIPS & MICS 5 These are both Medicaid programs. The MIP was created under the Deficit Reduction Act of 2005. MIP is intended to help reduce provider fraud, waste and abuse in the Medicaid program. CMS developed the Comprehensive Medicaid Integrity Plan which oversees the MIP through the MIC. There are 3 primary MICs: Review MICs to analyze Medicaid claims data looking for potential provider fraud, waste, and abuse Audit MICs audit provider claims for overpayment Education MICs furnish provider education CMS is responsible to hire the MIC contractors and to support the program in combating fraud and abuse HealthCare Management Consultants 2013 WHAT THE MIC AUDITS LOOK FOR 6 Incomplete documentation Conflicting documentation Improper coding Duplicate billing Providing services that aren’t medically necessary Patient privacy breaches HealthCare Management Consultants 2013 MAC 7 The MAC is the regional Medicare carrier. In Oregon, the MAC is represented by Noridian Healthcare Solutions and the majority of Medicare claims are submitted directly to Noridian. The MAC puts claims through a pre-payment edit, that includes all LCDs, NCCI edits, MUE edits, etc. If they pass the edit, then the MAC employs formulas to determine and administer payment. Noridian works in conjunction with contractors conducting the CERT audit, which is an annual random audit of a statistically valid volume (about 50k) of Medicare FFS claims. Noridian also provides education through a variety of resources. HealthCare Management Consultants 2013 MAC AUDITS 8 The MAC can audit any claim at any time, but does not audit all claims Focus on claims with the potential to be non-covered or incorrectly coded High volume of services High cost Dramatic change in frequency of use High risk problem-prone areas MAC notifies provider in writing prior to beginning provider- specific audit. Notice will indicate if this will be a pre or post payment review and the reason for the audit. Notice will be sent by certified mail. HealthCare Management Consultants 2013 CERT CONTRACTORS/ RESPONSIBILITIES: OREGON 9 AdvanceMed, a Program Safeguard Contractor (PSC), administers the activities of the CERT program. As the CERT Review Contractor, AdvanceMed is responsible for: Selecting a random sample of claims that have been received by each Medicare contractor every month. Reviewing the selected claims and associated medical record documentation to determine if the claim was appropriately adjudicated according to Medicare regulations/guidelines. Livanta’s role as the CERT documentation contractor is to streamline the record request and receipt functions. The CERT Documentation Contractor is responsible for: Requesting and receiving medical record documents; Maintaining a document tracking system; Providing a website for updating supplier addresses and contact information; Scanning the medical records into a retrieval system; and Operating a call center to answer contractor and supplier questions regarding CERT HealthCare Management Consultants 2013 CERT AUDIT FINDINGS 2012 10 TOP 20 SPECIFIC SERVICE TYPES: HIGHEST IMPROPER PAYMENTS: PART B 1 Chiropractic 11 Subsequent Inpatient Care 2 Initial Inpatient Care 12 Dialysis Services 3 Hospital: Critical Care 13 MRI/MRA 4 Lab Tests – Blood Counts 14 Other Tests 5 Lab Tests, other (non-MC fee schedule) 15 Established Office Visit 6 Minor Procedures 16 ED Visits 7 Oncology: Radiation Therapy 17 Lab Tests (MC Fee Schedule) 8 NP Office Visits 18 Ambulatory Procedures: Skin 9 Nursing Home Visits 19 Ambulance 10 Specialist: Psychiatry 20 Other Drugs HealthCare Management Consultants 2013 THE RAC 11 The mission of the RAC is to reduce improper Medicare over payments. Their methodology is data mining based on claims data. Based on this methodology, they also identify underpayments. RACs investigate specific measures identified and approved by Medicare RAC contractors are paid on a contingency basis – Contingency fees range from 9.0% - 12.5% for all claims except DME – Contingency for DME is from 14.0% to 17.5% The RAC may request up to 500 records every 45 days, which poses huge operational concerns for provider offices HealthCare Management Consultants 2013 RAC COLLECTIONS: 2011 12 Identify & correct $939.3m in improper payments $797.4m overpayments $141.9m underpayments CMS spent $129.4m to operate the Medicare FFF Recovery Audit Program. $89.9m paid in contingency to RAC contractors $47.5 paid in administrative costs Net returned to Medicare Trust Fund FY 2011: $488.2 HealthCare Management Consultants 2013 RAC MEASURES 13 As of 09/01/2013, there 664 RAC measures; 69 of them added this year New measures for 2013 targeted at Physician/NPP professional services include: Medically unlikely billed dosages of drugs and biologicals Incorrect billing of drugs and biologicals Excessive units of new patient visits Outpatient hospital stays billed as inpatient Post-payment review of therapy claims above $3,700 threshold Other specialty-specific measures involving Urology, Radiology, Lab/Pathology, Ophthalmology, and Interventional Radiology. HealthCare Management Consultants 2013 RAC TRANSITIONS 2013 14 Medicare has begun to transition to the new Medicare FFS Recovery Audit Program. A Request for Quote has been issued. The new program with have 4 Medicare A/B Recovery Contractors, 1 DME Recovery/Contractor, and 1 Home Health/ Hospice Recovery Contractor. ADR requests are expected to decline beginning in June; prepayment and postpayment reviews are expected to continue without decline There is also an ongoing Prepayment Review Demonstration project focusing on seven error-prone states. The intent is to lower the error rate by preventing improper payment rather than trying to identify and recoup overpayments after payment has been made. HealthCare Management Consultants 2013 ZPIC 15 ZPIC’s role is to identify potential Medicare fraud within a service area by review of past and pending claims ZPIC’s reviews are not random - the provider is under investigation for potential fraud Investigations are initiated by: Data analysis Complaints Referral from other agency (MAC, RAC, etc) Auditor may come onsite May conduct interviews with beneficiaries or provider’s employees, etc. HealthCare Management Consultants 2013 WHAT ZPIC AUDITS FOR 16 Identify areas of potential errors (i.e., noncovered or incorrectly coded) that pose greatest risk. Establish baseline data for comparison Identify need for LCD and/or education Identify high volume services that are overutilized Identify program errors or specific providers for possible fraud investigations Determine if findings by other MC auditing agencies represent significant problem areas ZPIC audits to confirm fraudulent behavior, not to discover it HealthCare Management Consultants 2013 OIG 17 The OIG has been supervising audits and fraud/abuse investigations since 1993. These are not limited to Medicare – the intent is to minimize loss in all government programs. The OIG may work an investigation alone or in conjunction with other agencies (i.e., as part of a HEAT investigation) The OIG has the ability to determine fines, and to exclude individuals and entities who have engaged in fraud from Medicare/Medicaid/other federal health care programs. HealthCare Management Consultants 2013 OIG ENFORCEMENT ACTIONS 2012 18 Opened 1,131 new criminal health care fraud investigations against 2,148 potential defendants 2032 investigations already opened, involving 3410 potential defendants; filed charges in 452 cases involving 892 defendants 826 individuals convicted 885 new civil investigations opened 1023 civil investigations pending at year end HealthCare Management Consultants 2013 Per OIG Annual Report for 2012 2012 RESULTS 19 Monetary Settlements: Won or negotiated $3.0 billion in judgments & settlements Exclusionary Actions Excluded 3,131 individual and entities HealthCare Management Consultants 2013 Per OIG Annual Report for 2012 OIG AUDIT PLAN 2013 (MEDICARE PART A & B: SPECIFIC TO PHYSICIANS) 20 Noncompliance with assignment rules and excessive billing of beneficiaries Error rate for incident-to services performed by nonphysicians Place of service coding errors Potentially inappropriate E/M services in 2010 E/M services: use of modifiers during global surgery period HealthCare Management Consultants 2013 HEAT TASK FORCE 21 HEAT’s MISSION To gather resources across the government to help prevent waste, fraud, and abuse in the Medicare and Medicaid programs. To crack down on the people and organizations who abuse the system and cost Americans billions of dollars each year. To reduce health care costs and improve quality of care by preventing fraudsters from preying on people with Medicare and Medicaid. To highlight best practices by providers and organizations dedicated to ending waste, fraud, and abuse in Medicare. To build upon the existing partnerships between HHS and DOJ to reduce fraud and recover taxpayer dollars. HealthCare Management Consultants 2013 Excerpt Stop Medicare Fraud website WHY AUDITS ARE NECESSARY 22 Medical claims payment program is on the honor system – only about 5% of submitted claims are reviewed The payment system is a target for deliberate, organized and systematic fraud A small amount of deliberately fraudulent entities responsible for a significant amount of dollars lost in the Medicare/Medicaid program May 2013: HEAT coordinated nationwide takedown – 89 participants in 8 cities involving $223 million in false billings HealthCare Management Consultants 2013 FRAUD EXAMPLE: MAY 2013 HEAT “TAKEDOWN” 23 Miami: 25 defendants, $44m in home health care fraud Baton Rouge: 5 defendants, $51m in home health care fraud Houston: 2 defendants, $8.1m in home health care fraud LA: 13 defendants 23m , including 3 defendants & $8.7m in DME fraud Detroit: 18 defendants, $49m in medically unnecessary services Tampa: 9 defendants, pharmacy fraud, money laundering, billing for surgeries not performed Chicago: 7 defendants with various health care fraud schemes Brooklyn: 4 defendants; $9.1m in false claims & 3 defendants, $15m in unlicensed massage therapy billed as physical therapy HealthCare Management Consultants 2013 MAY 2013 “TAKEDOWN” INDICTED AS PARTICIPANTS 24 Physicians (9) Nurses Paramedics Radiographer Home Health agency Community mental health center Social worker Physician Assistant Therapists Health care clinics & Rehab facility HealthCare Management Consultants 2013 2013 FRAUD CASE STATISTICS (so far) 25 28 states 145 settled cases 28 publicly reported cases pending Reported per HEAT September 2013 HealthCare Management Consultants 2013 THE AFFORDABLE CARE ACT & FRAUD INVESTIGATION 26 The Affordable Care Act, the health care law, takes powerful steps toward combating health care fraud, waste, and abuse. The government has recovered a record-breaking $10.7 billion in recoveries of health care fraud in the last three years. Tough new rules and sentences for criminals: The law increases federal sentencing guidelines for health care fraud by 20-50% for crimes with over $1 million in losses. Enhanced screening: Providers and suppliers who may pose a higher risk of fraud or abuse are now required to undergo more scrutiny, including license checks and site visits. State-of-the-art technology: To target resources to highly suspect behaviors, the Center for Medicare & Medicaid Services now uses advanced predictive modeling technology. New resources: The law provides an additional $350 million over 10 years to boost anti-fraud efforts HealthCare Management Consultants 2013 Excerpt Stop Medicare Fraud website MEDICARE AUDIT GOAL by 2012 27 Reduce overall payment errors by $50 billion Cutting Medicare fee-for-service error rate by 50% Recovering $2 billion in improper payments HealthCare Management Consultants 2013 S.1012: MEDICARE AUDIT IMPROVEMENT ACT OF 2013 28 Introduced in the Senate May 22, 2013 Assigned to committee same date Predicted: 1% chance of getting past committee; 0% chance of being enacted Highlights: Would establish a combined annual limit of audit requests from federal agencies Provide for auditor penalties when appeals are successful Publish RAC performance information, including audit rates, denials, appeals outcome and performance reviews Physician review for each RAC claim denial if denial determination is made by a non-clinician HealthCare Management Consultants 2013 RISK FACTORS: MYTH vs REALITY 29 Myth: 1a. 1b. 1c. 2. 3. Only large groups get audited Only urban practices get audited Only specialists get audited “I’ve never been audited” “An reasonable physician would understand my documentation I can explain my position to the auditor and prevail” Reality 1a.b.c Provider risk is based on provider practice patterns, regardless of the size, location, and type of practice 2. Any request by a carrier for a chart note is an audit – if you’ve submitted a chart note at the carrier’s request, you’ve been audited 3. Hmmmmmmmm HealthCare Management Consultants 2013 - RISKY BEHAVIOR 30 Reporting high volume of high level codes without the ability to support them High volume unsupported or unbelievable time coding Inappropriate use of prolonged service codes Inappropriate application of “incident to” or “shared/split services” Inappropriate use or authentication of “scribes” or authentication of scribe role Billing a payable code instead of the non-covered service actually accomplished Billing for ancillary diagnostic services without medical necessity Billing for procedures or ancillary diagnostic services and manipulating the diagnosis code to assure coverage Billing time-coded psych services without documenting the time in the chart note HealthCare Management Consultants 2013 RISKY BEHAVIOR 31 Specialty practice: every new problem is a new patient encounter Billing higher for work comp because of the “psycho-social considerations” involved and the support required Every surgical case is billed with a modifier 22 Every post op encounter is a billed with an E/M code and a modifier 24 Every pre-op is billed (even though the decision for surgery was made 2 weeks ago) and there is no medical necessity to support the service Unbundling services Billing for services not accomplished Billing “never” events – like amputation on the same body part – multiple times Churning HealthCare Management Consultants 2013 RISKY BEHAVIOR: EHR VULNERABILITY 32 Cloning Automatic “pull through” documentation “Click” documentation Contradictory documentation Unreviewed/incomplete documentation (VRS errors) Garbled documentation Poor documentation Authentication (not signed/no title, etc) Automatic inclusion “one size fits all” time-coding statement Time coding doesn’t match imbedded system time stamps Printed chart notes don’t contain patient identifier on each page Medical Necessity not supported HealthCare Management Consultants 2013 WOULD YOU REIMBURSE THIS? 33 Excerpt from exam portion of E&M: “His liver alert and oriented x3 shows a deficit of cognitive function are thought physical psychosomatic eye pupils equal and rectal exams are normal her eczema with inflammation”. Excerpt from HPI: “She has insomnia-she takes her temazepam at HS-she is gestating at least 5 hours at night” Excerpt from Noridian Part B News, July 2011 Notes reviewed in a CERT audit HealthCare Management Consultants 2013 Hi, I’m a 99214…….Really? 34 CC: follow-up HPI: John returns, feeling great. No chest pain, no shortness of breath. No problems with meds; going to Arizona for the winter. ROS: All other systems negative PFSH: Meds reviewed and updated – no changes; still smoking Exam: Vital Signs: BP 120/80; Ht 6ft; Weight 205 General Appearance: NAD Psych: Normal mood and affect Labs: Normal Assessment: Diabetes, Hypertension, Hypercholesteremia, all stable Plan: No changes, follow-up in Spring after return from Arizona HealthCare Management Consultants 2013 TIME CODING STATEMENTS (that don’t work) 35 I spent more than half of a 25 minute visit reviewing the management and treatment options for the conditions listed above.” (stated on every patient encounter for the day) “More than half of a 45 minute visit spent face to face with the patient.” (what did they do for the rest of the encounter?) HealthCare Management Consultants 2013 WHAT IS AN AUDIT? 36 A request from a carrier for a chart note in order to make payment A request from an auditing entity to return money for an individual or multiple claim based on identified error A request from an auditing entity (i.e. OIG) for a volume of specific chart notes for review based on identified issues Appearance of a sanctioned auditor in the office with a request for specified chart notes for review Based on the situation, the audit may be either a pre-payment or a post-payment review HealthCare Management Consultants 2013 POTENTIAL MAJOR AUDIT CONSEQUENCES 37 Return of overpayments Extrapolation Fines - up to treble damages per occurrence Exclusion from Medicare – and all other federally funded carriers (Medicare HMO, Medicaid, TriCare, etc) Development of a CIA (Corporate Integrity Agreement) Potential compromise of practice financial viability Criminal charges, if deemed appropriate IRS issues, if deemed appropriate Stripes? HealthCare Management Consultants 2013 FREQUENT AUDIT TRIGGERS FOR CREDIBLE MEDICAL PRACTICES 38 TYPE OF SERVICE PROBLEM IDENTIFIED BY E/M Services Consistent Over-Coding Provider Profile compared to national by-specialty profile Surgery Unbundling services NCCI edits Coding Guidelines Inappropriate use of time coding Chart review Coding Guidelines Inappropriate use of Chart review Incident to or shared/split services Coding Guidelines Cloning Chart review Clinical Guidelines Churning Comparison to clinical standards of care All of the above HealthCare Management Consultants 2013 Whistle blower WHAT ELEVATES YOUR RISK 39 Misunderstanding of coding guidelines Misunderstanding of levels of service application “Half-knowledge” or lack of knowledge Mistake by provider or staff “Don’t know, don’t want to know, won’t change” HealthCare Management Consultants 2013 REDUCING YOUR RISK: PREVENTION 40 Oversight: Develop, Implement & follow a credible Compliance Plan Operational policies and procedures, including: Development of an Audit/Provider Education Team Assign role of internal “External Audit Expert” Receipt & Processing Audit Requests Development of electronic reports & analysis of provide coding patterns Development of electronic audit tracking tools Development of action plans Operational actions, including: Internal/External audits Internal/External education Documentation improvement HealthCare Management Consultants 2013 EDUCATION 41 You are required to know the rules, regardless of how many rules there are, and how many exceptions there may be to the rules If a provider understands and applies the rules correctly, mistakes that result in costly audits are less likely to occur HealthCare Management Consultants 2013 IMPORTANCE OF A COMPLIANCE PLAN 42 Sets the tone of your program Base it on reality – you have to live up to it Set standards Address risk areas Address corrective action plan Develop policies and procedures in support Developing a corresponding training program Develop lines of communication HealthCare Management Consultants 2013 OIG: RECOMMENDED COMPONENTS OF A SMALL PRACTICE COMPLIANCE PLAN 43 1. 2. 3. 4. 5. 6. 7. Internal Auditing & Monitoring Practice & Procedures Establish Practice Standards & Procedures Designation of a Compliance Officer/Primary Contact Conducting Education & Training Responding to Identified Issues & Corrective Action Plans Developing Open Lines of Communication Enforcing Disciplinary Standards See OIG Compliance Program for Individual and Small Group Physician Practices October 5, 2000 HealthCare Management Consultants 2013 SAMPLE: EXTERNAL AUDIT EXPERT ROLE 44 Identify different audit entities Know the audit scope, if any, for each entity Distinguish type of audits based on agency Know their time lines and procedures for response Develop communication forms Review all audit requests Manage and track responses Develop lines of communication with audit entities Communicate internally to facilitate change where necessary HealthCare Management Consultants 2013 SAMPLE PROCEDURE: RECEIPT & PROCESSING AN AUDIT REQUEST 45 Audit requests are time-limited – do not let them sit in an “in box” during any step in the process Policy should indicate a specific individual to receive the request On Master Log, log in the request Name/MRN # of patient Note and document the date of receipt Note the date response is due Date of service information is requested for List of information requested Document who is requesting the information HealthCare Management Consultants 2013 SAMPLE PROCEDURE: RECEIPT & PROCESSING AN AUDIT REQUEST 46 Read and assess the request What exactly is the audit looking for Determine the validity of the request Understand why the request was made and if provider/staff behavior triggered request Read and assess the chart notes If there is an allegation of error or wrong doing, does the documentation refute it? Does the documentation support the codes reported Were modifiers appropriately applied Is the note legible, properly authenticated and signed Does the note reference previously documented information (i.e., “refer to health history form”) Never send original documents HealthCare Management Consultants 2013 SAMPLE PROCEDURE: RECEIPT & PROCESSING AN AUDIT REQUEST 47 Make two copies of all requested and referenced information Page number everything being sent Based on the request, understand what to send and what not to send If the chart note references another document like the Health History form, copy and include it Question: enclose test results or not? Don’t fabricate documentation if it isn’t there, it isn’t there Double check that everything being sent is for the requested date of service HealthCare Management Consultants 2013 SAMPLE PROCEDURE: RECEIPT & PROCESSING AN AUDIT REQUEST 48 Copy the request Review the copies for copy legibility (i.e., copy isn’t too light, too dark, full page copied, appropriate orientation, etc) Don’t write directional notes on the copy Clip one copy of the copied records and the copy of the request together (Set 1); request on top of records Clip the other set of copied records and the original request together (Set 2); request on top of records (to be retained, so you know exactly what was submitted) If the request includes multiple patients, there should be a set for each individual patient. Highlight the patient name on each set HealthCare Management Consultants 2013 SAMPLE PROCEDURE: RECEIPT & PROCESSING AN AUDIT REQUEST 49 Prepare Set 1 for submission Note any specific information about how the information is to be received (mail, fax, etc.) and two whose attention it should be sent Send as directed If there is no direction on how the packet is to be sent, options are: Fax .pdf files Open mail Tracked mail Preference is always tracked mail with a return receipt requested; some groups also submit by fax – noting this is a fax copy, with hard copy also on the way HealthCare Management Consultants 2013 SAMPLE PROCEDURE: RECEIPT & PROCESSING AN AUDIT REQUEST 50 • On Master Log, log in date sent, to whom and method of transmission • File Set 2 as pending • Track for claim adjudication/carrier response • Facilitate provider/staff education, if request is generated by need for education and/or change HealthCare Management Consultants 2013 SUBMISSION TIMELINES 51 MACs, RACs, CERT, & ZPICs Pre-payment Review Time Frames Submit w/n 30 calendar days of request No extensions granted Claim denied if requested data not received by day 45 Post-payment Review Time Frames MAC, CERT, RAC: submit w/n 45 calendar days of request ZPIC: submit w/n 30 calendar days of request MAC, CERT, ZPIC have discretion to grant extensions Refer to Medicare Program Integrity Manual, Chapter 3 for detailed guidelines on submission, including timelines, submission methods and additional information HealthCare Management Consultants 2013 WHAT AUDITORS MAY REQUEST 52 At minimum. Auditors will require your chart notes for review. They may also request other information, including: Referenced data not initially provided Appointment schedules Time stamp logs Chart notes for dates before and after the reviewed date (looking for cloning) Diagnostic tests HealthCare Management Consultants 2013 APPEALS PROCESS 53 Level 1: Level 2: Level 3: Level 4: Level 5: Redetermination by a Medicare Contractor Reconsideration by a Qualified Independent Contractor (QIS) Hearing Before an Administrative Law Judge (ALJ) Review by the Appeals Counsel Judicial Review in Federal District Court HealthCare Management Consultants 2013 For details and timelines for each level of appeal, -see CMS MLN “The Medicare Appeals Process” AUDIT TIPS 54 Treat every request seriously, even if it’s a request for a single note for clarification of a service for claims payment – it’s still an audit Educate based on audit request findings Pay attention to time lines for submission Clarify & communicate “chain of command” for incoming documents related to carrier communication Private carriers may audit just as actively as Medicare Know when to involve your health care attorney HealthCare Management Consultants 2013 OTHER ACRONYMS USED IN THIS PRESENTATION 55 ACRONYM TRANSLATION CMS Center for Medicare & Medicaid Services LCD CMS Local Coverage Determinations NCCI National Correct Coding Initiatives MUE Medically Unlikely Edits FFS Fee for Service CIA Corporate Integrity Agreement HHS Health & Human Services ADR Additional Documentation Request AC Affiliated Contractor RA Remittance Advice MLN Medicare Learning Network HealthCare Management Consultants 2013 RESOURCES & WEBSITES 56 Noridian Healthcare Solutions https://www.noridianmedicare.com/ Health Data Insights http://www.healthdatainsights.com/ OIG http://www.oig.doc.gov/Pages/default.aspx Medicare Program Integrity Manual http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Internet-OnlyManuals-IOMs-Items/CMS019033.html AHIMA http://www.ahima.org/ HealthCare Management Consultants 2013 RESOURCES & WEBSITES 57 Federal Register (OIG Compliance Plan) https://oig.hhs.gov/authorities/docs/physician.pdf Recovery Auditing Program for FY 2011 http://www.cms.gov/Research-Statistics-Data-and-Systems/MonitoringPrograms/Recovery-Audit-Program/Downloads/FY2011-Report-To-Congress.pdf HEAT http://www.stopmedicarefraud.gov/aboutfraud/heattaskforce/ Senate Bill S.1012 http://www.govtrack.us/congress/bills/113/s1012#summary/libraryofcongress 2012 CERT ERROR TYPES top 20 http://www.cms.gov/Research-Statistics-Data-and-Systems/MonitoringPrograms/CERT/Downloads/AppendicesMedicareFeeforService2012ImproperPayment sReport.pdf HealthCare Management Consultants 2013 RESOURCES & WEBSITES 58 CMS MLN: The Medicare Appeals Process http://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNProducts/downloads/medicareappealsprocess.pdf CMS MLN: Medicare Claim Review Program http://www.cms.gov/Outreach-and-Education/Medicare-Learning-NetworkMLN/MLNProducts/downloads/MCRP_Booklet.pdf HealthCare Management Consultants 2013 Thank you for participating today! Your presentation by: 59 CAROL WINTERMUTE, ACS-EM H E A LT H C A R E M A N A G E M E N T C O N S U LTA N T S 7 0 7 0 S W 1 6 9 TH B E AV E R TO N , O R E G O N 97007 C O N TA C T U S : PHONE: 503-591-7264 FA X : 5 0 3 - 8 4 8 - 4 6 6 4 W I N T E R M U T E M C @ C O M C A S T. N E T HealthCare Management Consultants 2013