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Changing Hospice Certifying Physician Enrollment:  Starting in June, Physicians Must Be Enrolled or Opted-Out of Medicare for CMS...

On April 26, 2024, the Centers for Medicare and Medicaid Services (CMS) issued Questions and Answers concerning new hospice enrollment requirements for certifying physicians (CMS Q&As). In a nutshell, as of June 3, 2024, the...more

CMS Allows for the Coverage of Marriage and Family Therapists and Mental Health Counselors Services

For the first time, Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) can enroll as Medicare providers under provisions established in the Consolidated Appropriations Act of 2023. MFTs and MHCs can...more

Billing Medicare or Medicaid? Understanding Your Audit Risk

If you are a healthcare provider enrolled with Medicare and Medicaid, it is imperative that you know the governmental agencies’ expectations for compliant billing and understand that the agencies constantly monitor and audit...more

The End of PHE Flexibilities – How to Navigate Upcoming Changes in Healthcare

On January 30, 2022, President Biden announced that the Covid-19 Public Health Emergency (PHE) will finally end on May 11, 2023.[1] Since the PHE was declared on January 31, 2020, emergency declarations and waivers were...more

CMS Designates More Providers as “High Risk”

On November 23, 2022, the Department of Health and Human Services and the Center for Medicare and Medicaid Services (“CMS”) passed a final rule that drastically changed the risk categories for certain providers when they...more

CMS Revocation and Preclusion: The “Secret” Exclusion

On April 1, 2019, the Center for Medicare and Medicaid Services (“CMS”) announced a new exclusion sanction: the CMS Preclusion List. This lesser-known sanction is different than placement on the Office of Inspector General...more

SMRC Intensified Auditing in 2021: What is a Supplemental Medical Review Contractor and What Are They Auditing?

The year 2020 saw much less medical review auditing, including a CMS suspension of audits between March 30 and August 3 of 2020. However, with the lifting of the CMS suspension, the CMS Supplemental Medical Review Contractor...more

Behavioral Health Scores a Big Win with Telehealth Waivers During Pandemic, but Audit Risks are High

BackgroundPrior to the current public health emergency (PHE), Medicare allowed for coverage of telehealth services primarily in rural areas where beneficiaries had difficulty accessing quality health care. Based on the...more

Health Care Reimbursement: Experience Matters. The Who, What, When, Where, and Why of Healthcare Reimbursement Coverage,...

The laws and policies surrounding the financial relationship between payors and healthcare providers is healthcare reimbursement law. Our attorneys and consultants have broad experience handling matters involving the full...more

Proactive Coding Compliance: The Best Way to Avoid the CMS Administrative Appeal Process

As an attorney specializing in healthcare reimbursement, I have focused my practice on helping healthcare providers navigate the Center for Medicare and Medicaid (“CMS”) administrative appeal process. I usually get a call...more

Staying Ahead of Changes to the Bad Debt Rule

CMS has made dramatic rule changes that reduce administrative barriers to assist Medicare providers during this public health emergency. Many Medicare providers are struggling to maintain financial viability due to a decrease...more

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