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In order to avoid erroneous billing practices for “New Patient” Evaluation and Management services, CMS issued Change Request 8165 which informs Medicare contractors about changes to Medicare’s Common Working File system that detects errors in billing.  According to Medicare manuals, “New Patient” is defined as: a patient who has not received any professional services, i.e., Read more →

On February 8, 2013, CMS issued a final rule intended to increase public awareness of financial relationships between manufacturers of drugs, devices, biological and medical supplies.  The rule also seeks to reveal relationships between Group Purchasing Organizations (GPOs), and physician and teaching hospitals.  The final rule, titled: “Medicare, Medicaid, Children’s Health Insurance Programs; Transparency Reports Read more →

In Glynn v. Edo Corp., 710 F.3d 209 (4th Cir. 2013), the Fourth Circuit recently clarified what constitutes “protected activity” under the anti-retaliation provision of the False Claims Act, 31 U.S.C. § 3730 (h)(1). As background, to prove a FCA retaliation claim, a whistleblower must show, inter alia, that he was engaged in “protected activity” Read more →

On May 8, 2013, the Department of Health and Human Services Office of Inspector General (HHS-OIG) released a Special Advisory Opinion regarding Medicare Providers’ obligations to ensure that they do not employ or contract with excluded providers or entities in connection with the provision of Medicare services. The provision against employing or contracting with excluded Read more →

Beginning April 15, 2013, additional documentation limits will be implemented by the Centers for Medicare & Medicaid Services (CMS) for Medicare providers subject to the Medicare Fee-for-Service Recovery Audit Program. More specifically, the maximum documentation requests will be quantified per campus. Campus is defined as one or more facilities under the same Tax Identification Number Read more →