Knock Knock, Who’s There? Medicare! (Sponsored by Advance for PT and Rehab Medicine)
Previously considered a low risk with respect to the Medicare program, now physical therapists in private practice and CORFs have moved to a moderate risk category. Additionally private practice therapists who choose to become DME providers (for example hand therapists who fabricate and/or issue splints) will have their DME provider application default to the “high-risk” category with Medicare requiring additional application investigation, including but not limited to criminal background checks.
Join Nancy J. Beckley, MS, MBA, CHC, Nancy Beckley & Associates LLC and Lynn S. McGivern, LLM, JD on August 23 in this complimentary webinar. You will learn from actual case studies the differences between medical record requests and reviews by various CMS and OIG authorities. This webinar will also address the various fraud fighting agencies, what to expect from each if they knock on your door, and how to respond in a fashion that may protect the future of your business.
Medicare Compliance & Risk Management - Audio Conference with HCPro
Tuesday, April 19th, 1 PM (EDT)
GEM Educational Foundation Seminar on Compliance for Home Health
March 11, 2011, Chicago, IL – Establishing A Corporate Compliance Program Flyer
This day long seminar is targeted to home health agencies and will include the following topic areas:
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History of Compliance in Federal Healthcare Programs
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Compliance Guidance (OIG) for Home Health Agencies
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Compliance Case Studies
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How to Conduct a Risk Assessment
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Implication of the 2011 Final Rule for Compliance in Home Health Agencies
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Auditing and Monitoring
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Annual Compliance Training Requirements & Content
Registration and further information is available from the Gem Educational Foundation.
Private Practice Section, American Physical Therapy Association
November 3, 2010 Pre-Conference Workshop – Developing and Scaling A Compliance Plan to Address the Regulatory Risks in Your Therapy Practice
Recent OIG fraud cases involving physical therapy and rehab have identified therapy programs that have been able to mitigate treble damages by having an effective compliance program in place, albeit a program that was not implemented effectively in prevention of abusive and fraudulent activities. In most instances the OIG has noted that therapy practices did not have safeguards and systems in place to detect and prevent compliance issues of improper coding, improper billing, inadequate or missing documentation. The purpose of a compliance program is to DETECT offenses, CORRECT offenses and PREVENT offenses. This session is designed as a real time “working” practice compliance plan development session. Participants will get the tools and knowledge and template to complete an effective practice compliance program by developing their compliance plan master outline during the session presentation. The presentation will guide participants through a workbook format that when fully completed will form the basis of their practice compliance plan. Cases studies of effective compliance practices utilized in private practice therapy will be utilized and forms and outlines will be shared as part of this session. Case studies will show how the risk assessment related to the Recovery Audit Contractor Program and other Medicare fraud detection initiatives lead to internal audit activities and problem resolution which may include use of the Self Disclosure Protocol, refunds and/or employee disciplinary actions.
Private Practice Section, American Physical Therapy Association – Colorado Springs, CO, November 11-13, 2009
“Whistleblowers, Audits & Patient Complaints: Mitigating Practice Risk”
The OIG has published reports involving rehab providers: identifying cases of abuse and fraud resulting in Medicare paybacks, provider sanctions, negotiated settlement agreements, corporate integrity agreements, fines, civil monetary penalties, and practice closure. Flying under the radar are investigations of smaller practices as a result of staff and patient whistleblower complaints to the OIG and the United States Attorney, as well as patient complaints to the Office of Civil Rights. Do you have a whistleblower in your midst? Is there a chance that staff could have misunderstood your coding, billing, and productivity requirements? Have you taken the necessary steps to comply with the Office of Civil Rights requirements ensuring not only access but assistance requested by the hearing and visually impaired? Are you prepared for an investigation following a HIPAA complaint? Part 1: Recent & actual rehab case studies to reveal how quality rehab providers can get swept up in investigations not resolved in their favor; how to mitigate damages when under an investigation, and how to participate and effectively cooperate under progressive corrective action plans with your Medicare contractor and corporate integrity agreements with the OIG. Part 2: How to best defend through developmnet of an internal team the choice of an external term including experienced counsel, consultants and accounting assitatnce. Also reviewed wil be practical aspects of preparing for an audit, common mistakes when submitting medical records, and how to develop a proactive process to protect your practice from audit liability and practice.
HCCA Physician Practice Complance Conference – Philadelphia, PA, October 11-13, 2009
“Risky Business: Physical Therapy in the Physician Office”
The OIG has continued to target physical therapy and rehab services for review due to the consistently large error rate. The recent activity of the PSC, CERT and RAC contractors have given notice to the therapy industry that it will not be an easy battle if your services come under review. In the past several years CMS revised the therapy rules for physical therapy provided in physician offices that is billed “incident-to”, as well as overhauling documentation requirements. Physician practices offering therapy services stand to put their entire practice at risk unless physical therapy services are provided, documented, coded and billed in accordance with updated regulatory standards This session will provide expert guidance in establishing an effective rehab compliance program and attendees will be given tools to facilitate a proactive therapist driven approach to compliance in the physician office.
Chart Audit FormDownload
AMRPA Fall Meeting – San Antonio, TX, October 5-7, 2009
“The Fox is in the Hen House and the Door to the Outpatient Therapy Department is Open”
The importance of effective documentation has proven a necessity for survival in a RAC environment. Lessons learned from the RAC demonstration, particularly in California, have focused industry energy and efforts in understanding medical necessity and documentation requirements for inpatient rehab. Not all the lessons learned in inpatient necessarily apply to the outpatient rehab setting. While the regulatory concepts of medical necessity and skilled care remain the same, the requirements for documentation, including the plan of care, coding and billing, daily encounter notes, and progress notes are dramatically different. This session will explain Medicare outpatient documentation requirements, both national as well as the variances in the local coverage determinations. A 10 year progressive history of rehab fraud cases will be highlighted with the lessons from each case that provide valuable insight into preparing for the RACs. Key elements of effective compliance programs that protect outpatient rehab, with a focus on the risk assessment will be presented, along with a model auditing and monitoring program for outpatient rehab that can be effectively implemented. Sample audit forms will be presented.
Chart Audit FormDownload