PYA’s Tynan Olechny and Valerie Rock presented “How to Have a Successful Engagement and a Happily Ever After: ‘New Age’ Nuances to Physician Hospital Arrangements” with R. Ross Burris III of Polsinelli at the Health Care Compliance Association’s (HCCA) Regional Annual Conference.
PYA Presentation: “Thorny Issues in FMV and Commercial Reasonableness"PYA, P.C.
PYA Principals Jim Lloyd and Lyle Oelrich presented "Thorny Issues in Fair Market Value and Commercial Reasonableness" at the Greater Kansas City Society of Healthcare Attorneys, Wednesday, April 16, 2014.
Presentation Covers Physician Practice CompliancePYA, P.C.
PYA Consulting Manager Valerie Rock presented “Compliance in the Physician Practice.” She discussed the importance of having a compliance plan, coding and billing monitoring, audit schedules, and provider expectations.
Healthcare Valuations in an Era of Reform and UncertaintyPYA, P.C.
PYA Principal Jim Lloyd's AICPA Health Care Industry Conference presentation explored reform and current environment highlights, healthcare transactions and affiliations, valuation considerations, and regulatory issues.
PYA Presents Intro to Healthcare Valuation PYA, P.C.
PYA Principal Jim Lloyd, along with other presenters, provided a “Healthcare Valuation 101” during a pre-conference workshop at the 2013 AICPA Healthcare Industry Conference.
PYA Principal Jim Lloyd was among the faculty who spoke at the 2013 Mid-South Commercial Law Institute during a panel discussion on “Healthcare Facilities in Bankruptcy.” The presentation provided an overview of healthcare facilities and key issues, healthcare regulatory environment, valuation of healthcare facilities, and red flags for healthcare businesses in bankruptcy or distress.
Don’t Stumble Coming Out of the Gate –Top Ten Issues to Address When Acquirin...PYA, P.C.
PYA Consulting Principal Carol Carden co-presented with Charlene McGinty of McKenna Long. They examined the top issues to address when acquiring a physician practice and some of the common and more complex issues hospitals face during the acquisition.
Guarding Your Client's Valuation from Attack--Dos and Don'ts for Requesting, ...PYA, P.C.
During an AHLA webinar series roundtable discussion, “Guarding Your Client’s Valuation from Attack—Dos and Don’ts for Requesting, Reviewing, Using, and Discarding FMV Opinions,” PYA Principal Carol Carden joined other legal experts to explore the practical issues for counsel to consider when balancing the arguments for scrutinizing valuation reports with the arguments for ensuring valuator independence.
PYA Presentation: “Thorny Issues in FMV and Commercial Reasonableness"PYA, P.C.
PYA Principals Jim Lloyd and Lyle Oelrich presented "Thorny Issues in Fair Market Value and Commercial Reasonableness" at the Greater Kansas City Society of Healthcare Attorneys, Wednesday, April 16, 2014.
Presentation Covers Physician Practice CompliancePYA, P.C.
PYA Consulting Manager Valerie Rock presented “Compliance in the Physician Practice.” She discussed the importance of having a compliance plan, coding and billing monitoring, audit schedules, and provider expectations.
Healthcare Valuations in an Era of Reform and UncertaintyPYA, P.C.
PYA Principal Jim Lloyd's AICPA Health Care Industry Conference presentation explored reform and current environment highlights, healthcare transactions and affiliations, valuation considerations, and regulatory issues.
PYA Presents Intro to Healthcare Valuation PYA, P.C.
PYA Principal Jim Lloyd, along with other presenters, provided a “Healthcare Valuation 101” during a pre-conference workshop at the 2013 AICPA Healthcare Industry Conference.
PYA Principal Jim Lloyd was among the faculty who spoke at the 2013 Mid-South Commercial Law Institute during a panel discussion on “Healthcare Facilities in Bankruptcy.” The presentation provided an overview of healthcare facilities and key issues, healthcare regulatory environment, valuation of healthcare facilities, and red flags for healthcare businesses in bankruptcy or distress.
Don’t Stumble Coming Out of the Gate –Top Ten Issues to Address When Acquirin...PYA, P.C.
PYA Consulting Principal Carol Carden co-presented with Charlene McGinty of McKenna Long. They examined the top issues to address when acquiring a physician practice and some of the common and more complex issues hospitals face during the acquisition.
Guarding Your Client's Valuation from Attack--Dos and Don'ts for Requesting, ...PYA, P.C.
During an AHLA webinar series roundtable discussion, “Guarding Your Client’s Valuation from Attack—Dos and Don’ts for Requesting, Reviewing, Using, and Discarding FMV Opinions,” PYA Principal Carol Carden joined other legal experts to explore the practical issues for counsel to consider when balancing the arguments for scrutinizing valuation reports with the arguments for ensuring valuator independence.
Demystifying Commercial Reasonableness in Physician/Hospital TransactionsPYA, P.C.
PYA Principal Lyle Oelrich presented “Demystifying Commercial Reasonableness in Physician/Hospital Transactions” at the Georgia Society of Certified Public Accountants’ (GSCPA) 2016 Healthcare Conference, February 11, 2016, in Atlanta, Georgia.
Fair Market Value: What Rural Providers Need to Know PYA, P.C.
PYA Principal Tynan Olechny and Senior Manager Annapoorani Bhat provided important information for rural providers related to fair market value and commercial reasonableness considerations during a National Rural Health Association webinar, “Valuations: What Rural Providers Need to Know."
PYA Principal Carol Carden recently spoke on the topic “Valuation Issues in Healthcare” at the Tennessee Society of Certified Public Accountants’ Healthcare Conference.
Presentation Uncovers Trends in the Unpredictable Healthcare IndustryPYA, P.C.
With the healthcare industry in a state of flux, not much is known about what lies ahead; but trends across the industry have become apparent and are likely to stick. These trends were the subject of a presentation given by PYA Principal David McMillan at the PKF North America Healthcare Fly-In.
PYA Principal Carol Carden presented on current issues in healthcare valuation at The Texas Society of Certified Public Accountants Business Valuation, Forensic, and Litigation Services Conference at the Hilton Fort Worth, October 14, 2014.
PYA Senior Consultant Kathryn Culver presented "Fundamentals of Healthcare Valuation" before the Tennessee Society of Certified Public Accountants (TSCPA). The presentation:
Provided a healthcare valuation overview.
Discussed healthcare valuation approaches.
Covered healthcare valuation considerations and trends.
Big Data: Implications of Data Mining for Employed Physician Compliance Manag...PYA, P.C.
PYA Principal Denise Hall presented “Big Data: Implications of Data Mining for Employed Physician Compliance Management” at Becker’s Annual CEO & CIO Strategy Roundtables, November 18-19, 2015.
The presentation explored:
Data being aggregated by the government, as well as new approaches by regulators.
Public relations and litigation risk from the public dissemination of data by the government.
Big data connections to payment through quality metrics and the potential for new theories of False Claims Act (FCA) suits.
Internal use of broad spectrum analytics in employed physician compliance management.
Determination of risk tolerance and the customization of “outside the box” analytics.
Benchmarking, monitoring, and defining physician-focused risk area reviews.
The Heartaches Associated with Billing for Cardiac DevicesPYA, P.C.
PYA Principal Denise Hall-Gaulin and Consulting Manager Joanna Malcolm presented a free webinar for the Georgia chapter of the Healthcare Financial Management Association, on Tuesday, December 6, 2016.
The presentation was geared toward C-suite hospital leaders, compliance officers, in-house counsel, operational leaders, and patient accounting leadership, and covered:
The criteria for implantable cardioverter defibrillators (ICDs), pacemakers, and other devices
The documentation requirements for payment
The prerequisites for a clean audit
Commercial Reasonableness in Hospital-Physician TransactionsPYA, P.C.
PYA Principals Lyle Oelrich and Darcy Devine presented “Commercial Reasonableness in Hospital-Physician Transactions” to the Health Care Fraud Working Group in Memphis, TN, April 10, 2013.
PYA Healthcare Consulting Senior Manager Robert Mundy co-presented during, “Valuing Hospitals,” Thursday, July 31, at 1 p.m. EST. This webinar explores the changing world of hospital economics, regulations, and valuations and how appraisers can best prepare themselves for both the opportunities and challenges that lie ahead.
Affiliation Strategies for At-Risk Community HospitalsPYA, P.C.
PYA Senior Healthcare Consulting Manager Michael Ramey presented “Affiliation Strategies for At-Risk Community Hospitals” with Jay Hardcastle, partner at Bradley Arant Boult Cummings at the AHLA Health Care Transactions Program. The presentation helped:
1. Identify factors affecting the continued financial viability of community hospitals.
2. Introduce the importance of board/management being proactive in evaluating potential affiliation alternatives before reaching a dire state.
3. Discuss the request-for-proposal process.
4. Explore legal structures to retain the best value for the community via appropriate models (i.e., management agreement, lease, acquisition, joint operating agreement, joint venture, affiliation).
5. Provide lessons learned from recent hospital transactions.
Accounting Update Overview with a Healthcare SlantPYA, P.C.
PYA Principal and Director of Audit Services Doug Arnold presented during East Tennessee State University’s 38th Annual Accounting, Auditing, and Tax Updating CPE conference. His presentation covered many recent Accounting Standards Updates, but leaned toward their applications in healthcare.
PYA Principal Carol Carden's AICPA Health Care Industry Conference presentation addressed the current hospital/physician affiliation environment and its impact on physician compensation.
Forensic and Valuation Issues in HealthcarePYA, P.C.
PYA Principal Carol Carden co-presented “Forensic and Valuation Issues in Healthcare” at the AICPA Forensic & Valuation Services Conference in New Orleans, LA, November 10, 2014.
This presentation was given by Chris Carnahan on October 26, 2016 at the National Association of Certified Valuators and Analysts (NACVA) and the Consultants' Training Institute's (CTI) Exit Planning, Mergers and Acquisitions, and Transaction Advisory Services Conference. This piece discusses the valuation of a practice when a physician leaves. It will cover fair market valuation regulations, trends and marketplace data, as well as the Income, Market, and Asset Approach.
PYA Principal Carol Carden and Senior Manager Angie Caldwell presented “Hot Topics in Physician Compensation” at the Kentucky Society of CPAs (KY CPA) Health Care Conference, May 18, 2016. The presentation explored the latest developments in physician compensation structure, as well as considerations related to stacking compensation elements, the role and impact of quality incentives, the latest in affiliation models, and population health initiatives.
Office of Civil Rights HIPAA Audits Preparing Your Clients and YourselfPYA, P.C.
PYA Consulting Manager Susan Thomas presented “Office of Civil Rights HIPAA Audits – Preparing Your Clients and Yourself” at The Florida Bar’s “Representing the Physician: It Is Harder Than It Looks” conference, February 3, 2017, in Orlando, Florida.
The presentation covered topics that include:
The Health Information Technology for Economic and Clinical Health Act.
Phase 1 audit, privacy, security, and breach notification findings and lessons learned.
Phase 2 audits—scope and recipient selection.
HIPAA audit readiness and steps for preparing.
Personal reflections from an OCR breach investigation.
Audit resources for physician practices.
Certification+: The Most Comprehensive Compliance SolutionPYA, P.C.
PYA Principal Pete Pearson along with Glen Stout and Matt Froning from SCA and Chris Gulotta from Real Estate Data Shield presented “Certification+ The Most Comprehensive Compliance Solution” during a webinar for leaders within the Fidelity National Title Group, April 28, 2016.
The presentation explored:
• Market drivers related to the title industry and lender vendor programs
• Profiles of the Certification+ team
• Benefits to title agents who pursue Certification+
• Frequently asked questions
Demystifying Commercial Reasonableness in Physician/Hospital TransactionsPYA, P.C.
PYA Principal Lyle Oelrich presented “Demystifying Commercial Reasonableness in Physician/Hospital Transactions” at the Georgia Society of Certified Public Accountants’ (GSCPA) 2016 Healthcare Conference, February 11, 2016, in Atlanta, Georgia.
Fair Market Value: What Rural Providers Need to Know PYA, P.C.
PYA Principal Tynan Olechny and Senior Manager Annapoorani Bhat provided important information for rural providers related to fair market value and commercial reasonableness considerations during a National Rural Health Association webinar, “Valuations: What Rural Providers Need to Know."
PYA Principal Carol Carden recently spoke on the topic “Valuation Issues in Healthcare” at the Tennessee Society of Certified Public Accountants’ Healthcare Conference.
Presentation Uncovers Trends in the Unpredictable Healthcare IndustryPYA, P.C.
With the healthcare industry in a state of flux, not much is known about what lies ahead; but trends across the industry have become apparent and are likely to stick. These trends were the subject of a presentation given by PYA Principal David McMillan at the PKF North America Healthcare Fly-In.
PYA Principal Carol Carden presented on current issues in healthcare valuation at The Texas Society of Certified Public Accountants Business Valuation, Forensic, and Litigation Services Conference at the Hilton Fort Worth, October 14, 2014.
PYA Senior Consultant Kathryn Culver presented "Fundamentals of Healthcare Valuation" before the Tennessee Society of Certified Public Accountants (TSCPA). The presentation:
Provided a healthcare valuation overview.
Discussed healthcare valuation approaches.
Covered healthcare valuation considerations and trends.
Big Data: Implications of Data Mining for Employed Physician Compliance Manag...PYA, P.C.
PYA Principal Denise Hall presented “Big Data: Implications of Data Mining for Employed Physician Compliance Management” at Becker’s Annual CEO & CIO Strategy Roundtables, November 18-19, 2015.
The presentation explored:
Data being aggregated by the government, as well as new approaches by regulators.
Public relations and litigation risk from the public dissemination of data by the government.
Big data connections to payment through quality metrics and the potential for new theories of False Claims Act (FCA) suits.
Internal use of broad spectrum analytics in employed physician compliance management.
Determination of risk tolerance and the customization of “outside the box” analytics.
Benchmarking, monitoring, and defining physician-focused risk area reviews.
The Heartaches Associated with Billing for Cardiac DevicesPYA, P.C.
PYA Principal Denise Hall-Gaulin and Consulting Manager Joanna Malcolm presented a free webinar for the Georgia chapter of the Healthcare Financial Management Association, on Tuesday, December 6, 2016.
The presentation was geared toward C-suite hospital leaders, compliance officers, in-house counsel, operational leaders, and patient accounting leadership, and covered:
The criteria for implantable cardioverter defibrillators (ICDs), pacemakers, and other devices
The documentation requirements for payment
The prerequisites for a clean audit
Commercial Reasonableness in Hospital-Physician TransactionsPYA, P.C.
PYA Principals Lyle Oelrich and Darcy Devine presented “Commercial Reasonableness in Hospital-Physician Transactions” to the Health Care Fraud Working Group in Memphis, TN, April 10, 2013.
PYA Healthcare Consulting Senior Manager Robert Mundy co-presented during, “Valuing Hospitals,” Thursday, July 31, at 1 p.m. EST. This webinar explores the changing world of hospital economics, regulations, and valuations and how appraisers can best prepare themselves for both the opportunities and challenges that lie ahead.
Affiliation Strategies for At-Risk Community HospitalsPYA, P.C.
PYA Senior Healthcare Consulting Manager Michael Ramey presented “Affiliation Strategies for At-Risk Community Hospitals” with Jay Hardcastle, partner at Bradley Arant Boult Cummings at the AHLA Health Care Transactions Program. The presentation helped:
1. Identify factors affecting the continued financial viability of community hospitals.
2. Introduce the importance of board/management being proactive in evaluating potential affiliation alternatives before reaching a dire state.
3. Discuss the request-for-proposal process.
4. Explore legal structures to retain the best value for the community via appropriate models (i.e., management agreement, lease, acquisition, joint operating agreement, joint venture, affiliation).
5. Provide lessons learned from recent hospital transactions.
Accounting Update Overview with a Healthcare SlantPYA, P.C.
PYA Principal and Director of Audit Services Doug Arnold presented during East Tennessee State University’s 38th Annual Accounting, Auditing, and Tax Updating CPE conference. His presentation covered many recent Accounting Standards Updates, but leaned toward their applications in healthcare.
PYA Principal Carol Carden's AICPA Health Care Industry Conference presentation addressed the current hospital/physician affiliation environment and its impact on physician compensation.
Forensic and Valuation Issues in HealthcarePYA, P.C.
PYA Principal Carol Carden co-presented “Forensic and Valuation Issues in Healthcare” at the AICPA Forensic & Valuation Services Conference in New Orleans, LA, November 10, 2014.
This presentation was given by Chris Carnahan on October 26, 2016 at the National Association of Certified Valuators and Analysts (NACVA) and the Consultants' Training Institute's (CTI) Exit Planning, Mergers and Acquisitions, and Transaction Advisory Services Conference. This piece discusses the valuation of a practice when a physician leaves. It will cover fair market valuation regulations, trends and marketplace data, as well as the Income, Market, and Asset Approach.
PYA Principal Carol Carden and Senior Manager Angie Caldwell presented “Hot Topics in Physician Compensation” at the Kentucky Society of CPAs (KY CPA) Health Care Conference, May 18, 2016. The presentation explored the latest developments in physician compensation structure, as well as considerations related to stacking compensation elements, the role and impact of quality incentives, the latest in affiliation models, and population health initiatives.
Office of Civil Rights HIPAA Audits Preparing Your Clients and YourselfPYA, P.C.
PYA Consulting Manager Susan Thomas presented “Office of Civil Rights HIPAA Audits – Preparing Your Clients and Yourself” at The Florida Bar’s “Representing the Physician: It Is Harder Than It Looks” conference, February 3, 2017, in Orlando, Florida.
The presentation covered topics that include:
The Health Information Technology for Economic and Clinical Health Act.
Phase 1 audit, privacy, security, and breach notification findings and lessons learned.
Phase 2 audits—scope and recipient selection.
HIPAA audit readiness and steps for preparing.
Personal reflections from an OCR breach investigation.
Audit resources for physician practices.
Certification+: The Most Comprehensive Compliance SolutionPYA, P.C.
PYA Principal Pete Pearson along with Glen Stout and Matt Froning from SCA and Chris Gulotta from Real Estate Data Shield presented “Certification+ The Most Comprehensive Compliance Solution” during a webinar for leaders within the Fidelity National Title Group, April 28, 2016.
The presentation explored:
• Market drivers related to the title industry and lender vendor programs
• Profiles of the Certification+ team
• Benefits to title agents who pursue Certification+
• Frequently asked questions
Modern Physician-Hospital Affiliations in an Era of Increased Fraud and Abuse...PYA, P.C.
PYA Senior Manager Chris Beckham co-presented “Modern Physician-Hospital Affiliations in an Era of Increased Fraud and Abuse Scrutiny” with Ross Burris of Polsinelli at the American Health Lawyer Association’s (AHLA) Physicians and Hospitals Law Institute, February 8-10, 2016.
Remuneration strategy by derek hendrikz covers work definition, job grading, performance management and assessment, remuneration and total rewards strategies.
PYA Principal Scott Clay presented “Pacing Volume-to-Value Transition” at the AlaHA Annual Meeting, June 8-11, 2016.
The presentation explored volume- to value-based reimbursement, and how the pace of change is unique to each organization. The presentation introduced a strategic framework to establish and communicate a pace of change befitting various organizations, explaining:
How government policies “set the floor” on the degree of change requested.
How to determine the pace of change in your market.
How to identify your organization’s current position and culture in relation to value-based payment models.
How to set and communicate the pace of transition consistent with your market and your organization’s culture.
Big Data: Implications of Data Mining for Employed Physician Compliance Manag...PYA, P.C.
PYA Consulting Manager Kristen Lilly presented “Big Data: Implications of Data Mining for Employed Physician Compliance Management” during a webinar for the Georgia chapter of the Healthcare Financial Management Association (Georgia HFMA), March 31, 2016.
The presentation explored:
Public relations and litigation risk from the public dissemination of data by the government.
Internal use of broad spectrum analytics in employed physician compliance management.
Determination of risk tolerance and the customization of “outside the box” analytics.
Benchmarking, monitoring, and defining physician-focused risk area reviews.
Provider participation in accountable care organizations (ACOs) is becoming the new normal. As of January 1, 2016, there are 434 ACOs
in the Medicare Shared Savings Program. More than 160,000 providers now participate in an MSSP ACO. These organizations now serve
7.7 million Medicare beneficiaries residing in 49 of the 50 states. Here’s the road to the MSSP destination of shared savings.
PYA Principal Jim Lloyd along with Polsinelli’s Douglas Anning presented “Doing the Deal” in which they utilized case studies in analyzing both hospital-hospital transactions and hospital-physician practice transactions. The presentation also covered:
Helping clients successfully negotiate and structure the transaction and keeping the deal on track
Recognizing sample contract provisions common to these types of deals
Working with valuation firms to ensure the transaction terms are within fair market value and commercially reasonable
Evaluating and dealing with potential anti-trust concerns
Dealing with potential compliance issues identified during the due-diligence process
PYA Principal Martie Ross joined University of Kansas Medical Center’s Robert Moser, MD, and CIO Chris Hansen for the keynote presentation at the joint symposium by Heart of America Healthcare Information and Management Systems Society and Missouri Health Information Management Association, September 14, 2016, at Johnson County Community College in Overland Park, Kansas. They discussed insights related to the role of advanced analytics and technology in transforming and transitioning to new payment models.
PYA Principal Martie Ross presented the keynote address, “The March to MIPS: The Merit-Based Payment System,” at the Kansas Medical Group Management Association 2016 Fall Conference, September 21-23, 2016, at the Overland Park Marriott in Overland Park, Kansas.
The presentation will include:
An introduction to the Medicare Merit-Based Incentive Payment System (MIPS).
A discussion of the four components of the MIPS composite score.
An exploration of the penalties and bonuses associated with the MIPS composite score, as well as the reputational impact of the publicly reported MIPS composite score.
How to Engage Physicians in Best Practices to Respond to Healthcare Transform...PYA, P.C.
PYA Principal Kent Bottles, MD, spoke about physician engagement when it comes to value payment models during “How to Engage Physicians in Best Practices to Respond to Healthcare Transformation” at the Georgia Society of Certified Public Accountants’ (GSCPA) 2016 Healthcare Conference, February 11, 2016. Dr. Bottles discussed the difficulty of weaning physicians from fee-for-service payment models and the often-unappreciated reasoning behind the shift to value-based payment models. He also highlighted MACRA, MIPS, patient satisfaction surveys, Physician Compare, and the ProPublica Surgeon Scorecard.
Presentation Makes the Case for Enterprise Risk ManagementPYA, P.C.
PYA Principal David McMillan recently co-presented “Enterprise Risk Management” at the Massachusetts Continuing Legal Education 15th Annual Hospital & Health Law Conference.
At the Heart of the Matter: Medical NecessityPYA, P.C.
PYA Principal Denise Hall and Michael Spake, Vice President of External Affairs and Chief Compliance & Integrity Officer at Lakeland Regional Health System, co-presented “At the Heart of the Matter: Medical Necessity,” at the AHLA Institute on Medicare and Medicaid Payment Issues. They discussed:
Recent cases and legal actions
Impact of medical necessity when interpreting the regulations and guidelines for:
-Stents
-Pacemakers
-Automatic Implantable Cardiac Defibrillators (AICD)
-Electrophysiology Studies (EPS) and Ablations
Common areas of risk in applying local coverage determination (LCD)/national coverage determination (NCD) guidance to cardiac procedures: how to identify your risks and avoid vulnerability
Best practices for ensuring compliance with regulations
The Vicissitudes of Valuing Value--Legal and Valuation Issues Associated with...PYA, P.C.
PYA Principal Carol Carden co-presented “The Vicissitudes of Valuing Value--Legal and Valuation Issues Associated with Value-Based Payment Models” at the 2017 American Health Lawyers Association Physician and Hospitals Law Institute, February 1-3, 2017, in Orlando, Florida.
The presentation addressed:
Emerging alternative payment models (APMs)
The application of fraud and abuse laws and IRS rules to provider network payments
Existing market data and regulatory guidance
Considerations in determining fair market value and commercial reasonableness
Best Practices in Physician Arrangements: Combat Contract Compliance ConcernsPYA, P.C.
OIG This presentation highlights the importance of regulatory requirements and the consequences of non-compliance for healthcare organizations that deal with physician arrangements.
Addresses regulatory considerations such as the Stark Law, Anti-Kickback Statute, and False Claims Act.
Explores additional risk areas such as OIG Fraud Alerts, Medicare Cost Report Certification, and the responsibilities of boards of directors.
Auditing Healthcare Focus Arrangements for Regulatory CompliancePYA, P.C.
PYA Principal Tynan Kugler and Consulting Manager Susan Thomas presented “Auditing Healthcare Focus Arrangements for Regulatory Compliance: Physicians, Management Services, Post-Discharge Care, Ambulance Services, and Specialty Care.” Their presentation:
- Describes what constitutes a focus arrangement for healthcare organizations.
- Explains the implications of Stark Law and Anti-Kickback violations, along with Corporate Integrity Agreement focus arrangement requirements.
- Discusses essential focus arrangement procedures to facilitate regulatory compliance.
- Provides an example design of an audit plan approach for focus arrangements.
PYA Considers the “Taxing” Developments Facing Healthcare OrganizationsPYA, P.C.
The recent American Health Lawyers Association’s 2013 Tax Issues for Healthcare Organizations conference offered valuable information related to healthcare industry reform and resulting tax implications and compliance.
PYA Senior Manager Susan Clark presented “Strategies for More Tax-Effective Physician Practice Acquisition Transactions.” The discussion included:
Transaction options
Key issues with buyers and sellers
Personal vs. enterprise goodwill considerations
Corporate practice of medicine doctrine
Allocations
How the Obama Administration has re-shaped the OFCCP into an aggressive enforcement arm of affirmative action and nondiscrimination compliance, and what it all means for your organization.
Commercial Payor Behavioral Health Audits: How to Avoid Getting Wiped OutEpstein Becker Green
The number of commercial payor audits of behavioral health facilities has been steadily rising, forcing closures of multiple treatment facilities, straining resources, and setting up an increasingly contentious conflict between treatment providers and payors.
This webinar will examine the most common issues arising in payor audits (including medical necessity; patient financial responsibility; and other issues asserted to constitute fraud, waste, or abuse) and the common arguments used as grounds for the nonpayment or recoupment of fees by insurers. The presenters will also review responsive strategies in commercial payor audits and examine defensive strategies and best practices to avoid fraud, waste, and abuse.
Presented by:
Paul D. Gilbert – Member, Epstein Becker Green
John A. Mills – Partner, Nelson Hardiman
Part of a "first Thursdays" fall webinar series hosted by Behavioral Health Association of Providers, Epstein Becker & Green, P.C., and Nelson Hardiman, LLP.
More info: https://www.ebglaw.com/events/how-to-avoid-getting-wiped-out-by-the-wave-of-commercial-payor-behavioral-health-audits-medical-necessity-and-waivers-of-co-insurance-and-deductibles/
These materials have been provided for informational purposes only and are not intended and should not be construed to constitute legal advice. The content of these materials is copyrighted to Epstein Becker & Green, P.C. ATTORNEY ADVERTISING.
Presentation Offers Valuation Strategies for Tax-Effective Practice TransactionsPYA, P.C.
PYA Principal Jim Lloyd co-presented a session at the 2013 AICPA Healthcare Industry Conference in New Orleans on “Valuation Strategies for More Tax-Effective Physician/Dentist Practice Transactions.”
Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, W...PYA, P.C.
The federal government is now making CARES Act Relief Fund payments to Medicare providers. These payments are not loans—they do not have to be repaid or forgiven. However, this money comes with strings attached.
During PYA’s 30-minute webinar, Provider Relief Fund Payments—What We Know, What We Don’t Know, What To Do Now, PYA Principals Martie Ross and Lori Foley discussed:
The source of the funds.
The required attestation process.
Compliance, tax, and audit concerns.
The webinar took place Friday April 17, 2020.
HIPAA compliance for Business Associates- The value of compliance, how to acq...Compliancy Group
HIPAA compliance for Business Associates has become critical as you deal with medical professionals. During this webinar we will explain the law and what Business Associates need to know and do and how to differentiate your firm to acquire new and maintain current clients.
In this webinar, we will discuss:
-The steps on how to become HIPAA compliant as a Business Associate
-What an effective BAA should include
-How to help existing and new healthcare clients with compliance
-Why it is important to differentiate yourself as HIPAA compliant
Health Reform Bulletin: Certification of Compliance with Electronic Transacti...CBIZ, Inc.
In this health reform bulletin, you will receive information on the proposed regulations relating to certification of compliance with the electronic transaction requirements of the Affordable Care Act (ACA). These rules are particularly significant to self-funded health plans and their sponsors.
Navigating Relationships Between Hospital and Physicians--Negotiating and Val...PYA, P.C.
Offering a broad understanding of laws and regulations in the healthcare industry, this presentation serves as a valuable training program for new associates and in-house counsel, and an excellent refresher for experienced health lawyers as well.
Health Plan Identifier! What is it and Why Do You Need It?benefitexpress
This webinar answers the following questions:
• What is a health plan identifer?
• Who has to get one?
• When is it used?
• How do you get it?
• What happens if the health plans do not get one?
Similar to How to Have a Successful Engagement and a Happily Ever After: “New Age” Nuances to Physician Hospital Arrangements (20)
“CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting”PYA, P.C.
PYA Principal Martie Ross spoke at the virtual North Carolina Healthcare Association Critical Access Hospital Statewide Meeting. The two-day event, “Quality Focus is a Finance Focus,” provided critical access hospital leaders with the opportunity to network and review data-informed strategies as well as updates to the Medicare Flexibility Program Project. It also provided guidance on federal compliance and tracking of Provider Relief Funds.
In “CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting,” Martie gave an overview of the history of distribution of those funds as well as regulations and guidelines including:
Statutory Language
Reporting Requirements
Use of Funds Calculation
Expenses
Risk Management
Martie presented Thursday, March 4, 2021.
If you would like guidance related to Provider Relief Fund regulations, or for assistance with any matter related to strategy and integration, compliance, or valuation, contact one of our PYA executives at (800) 270-9629.
PYA Presented on 2021 E/M Changes and a CARES Act Update During GHA Complianc...PYA, P.C.
The Georgia Hospital Association (GHA) Compliance Officers Roundtable, an active GHA group that meets quarterly and includes educational sessions featuring government representatives, industry experts, and other thought leaders speaking about compliance-related issues, conducted their latest meeting virtually. PYA Principals Lori Foley, Tynan Kugler, and Valerie Rock were among the presenters at this quarter’s event. In their session, they:
Described key elements associated with 2021 E/M changes, and strategies for preparation and implementation.
Explained the impact of 2021 E/M changes on physician compensation and contracting, including potential mitigation approaches.
Presented key components of Stark Law and Anti-Kickback Statute final rules.
Provided an update on the CARES Act.
The Compliance Certification Board offered CEUs for this event, which took place on Friday, December 4, 2020.
Webinar: “Trick or Treat? October 22nd Revisions to Provider Relief Fund Repo...PYA, P.C.
On October 22nd, the Department of Health and Human Services released revised Provider Relief Fund (PRF) reporting requirements. Under HHS’ September 19 directive, “lost revenue” was defined narrowly as a negative change in year-over-year patient care operating net income. Now, HHS will permit providers to use PRF funds to cover the difference between their 2019 and 2020 actual patient care revenue with some adjustments for COVID-related expenses. The October 22nd notice is available here.
PYA Principals Martie Ross and Michael Ramey hosted a complimentary 30-minute webinar, “Trick or Treat? October 22nd Revisions to Provider Relief Fund Reporting Requirements” on Thursday, October 29th.
“Regulatory Compliance Enforcement Update: Getting Results from the Guidance” PYA, P.C.
PYA Principal and Chief Compliance Officer Shannon Sumner and Consulting Senior Manager Susan Thomas presented “Regulatory Compliance Enforcement Update: Getting Results from the Guidance” at the virtual 2020 Montana Healthcare Conference. They reviewed the sources of regulatory enforcement and investigation information—guidelines, statutory updates, best practices, settlements, case studies, etc.—available to healthcare organizations. They will also discuss how to interpret and implement the guidance in order to strengthen the compliance function and protect the organization. The presentation covered:
Compliance regulatory requirements for healthcare organizations.
Guidance available for consideration in organizational compliance programs.
Internal and external reporting to ensure regulatory requirements are met.
Best practices for implementation of guidance.
Case studies for illustration of guidance implementation.
“Federal Legislative and Regulatory Update,” Webinar at DFWHCPYA, P.C.
The Dallas Fort Worth Hospital Council (DFWHC) and PYA co-hosted an exclusive complimentary webinar, “Federal Legislative and Regulatory Update,” on Wednesday, September 23.
DFWHC President/CEO Stephen Love hosted a discussion with PYA Senior Manager Kathy Reep about concerns that have dropped from the radar during the last four months of COVID-19, addressing issues for which hospitals must prepare in approaching 2021. This session focused on these key areas:
Appropriate use criteria
Transparency
Site neutral payments
The future of the Medicare Trust Fund
The federal budget
Key provisions of the final rule for the inpatient prospective payment system for FY2021 and the proposed outpatient rule for CY2021
On-Demand Webinar: Compliance With New Provider Relief Funds Reporting Requir...PYA, P.C.
On September 19, the Department of Health and Human Services (HHS) published its Post-Payment Notice of Reporting Requirements. The Notice details the reporting requirements for all Provider Relief Fund (PRF) recipients that have received $10,000 or more in aggregate payments.
Under the PRF Terms and Conditions, a recipient may use the funds only for healthcare-related expenses and lost revenue attributable to coronavirus. The Notice provides the clearest direction to date regarding permissible uses of PRF funds.
PYA offered a 45-minute complimentary webinar that explained the new reporting requirements and delved into permissible uses. While many questions remain, we provided practical advice on the next steps in the reporting process.
The webinar took place Monday, October 5 at 11 a.m. EDT.
Webinar: “While You Were Sleeping…Proposed Rule Positioned to Significantly I...PYA, P.C.
You likely know from the headlines that the 2021 Medicare Physician Fee Schedule (MPFS) Proposed Rule slashes payments for surgical specialists. But the impact of the Proposed Rule is far broader, reflecting a fundamental realignment driven by the transition to value-based payments. In our webinar, “While You Were Sleeping…Proposed Rule Positioned to Significantly Impact Physician Compensation,” PYA experts addressed these proposals, helping you understand and prepare for the changes ahead.
Following this presentation, attendees were able to:
Understand how a handful of wRVU changes would alter Medicare reimbursement for nearly all physicians.
Appreciate the operational impact of these changes.
Recognize the challenges to existing physician compensation models.
Identify strategies and tactics to prepare for and manage these impacts.
Presenters include PYA Principals Angie Caldwell, Martie Ross, and Valerie Rock. The webinar took place Thursday, September 10 and was hosted in conjunction with the Florida Hospital Association.
If you have additional questions about the MPFS Proposed Rule and its impact on physician compensation or need assistance with any matter involving physician compensation, valuation, strategy and integration, or compliance, contact a PYA executive below at (800) 270-9629.
Webinar: “Cybersecurity During COVID-19: A Look Behind the ScenesPYA, P.C.
Cybersecurity breaches have been in the news almost daily for some time now. COVID-19 has amplified the problem, as “bad actors” seize upon the opportunity to take advantage of hospitals at their most vulnerable time. Given this climate and an aging HIPAA rule, it is difficult to anticipate and prepare for the future.
PYA Principal Barry Mathis presented “Cybersecurity During COVID-19: A Look Behind the Scenes,” on Wednesday, August 12, 2020. This one-hour, complimentary webinar was hosted by PYA in conjunction with the Montana Hospital Association as Part 2 of the Frontier States Town Hall Meeting.
Barry covered information related to HIPAA, cybersecurity, and a special behind-the-scenes view into the tradecraft of bad actors. This unique presentation included:
Recent enforcement trends by the Office for Civil Rights.
The current environment for ransomware.
An opportunity to watch as Barry logs onto the Dark Web and shows you first-hand how bad actors operate.
Ideas for managing cybersecurity threats.
On Friday, August 21, 2020, a webinar co-hosted by PYA prepared hospitals for a new rule taking effect on January 1, 2021, to address price transparency in healthcare. The Centers for Medicare & Medicaid Services published a rule in November 2019 requiring hospitals to establish, update, and make public a list of their standard charges for items and services they provide. In addition to the current requirement to post standard charges on their websites, the Final Rule requires hospitals to publish online, in a machine-readable format, their payer-specific negotiated rates for 300 “shoppable” services and their standard charges for all items and services provided, defined as the gross charge, payer-specific negotiated charges, discounted cash price, and the de-identified minimum and maximum charges.
As we approach January 2021, it is vital that hospitals understand the requirements of the pricing transparency rule and options for compliance. It is unlikely that this rule will “go away”–court decisions are always subject to appeal, and there is even concern that Congress is considering action that would transform these requirements from regulation to legislation.
During the complimentary webinar, PYA Senior Manager Kathy Reep discussed hospital requirements related to pricing transparency, and Chris Kenny, Partner in the Washington, D.C., office of King & Spalding, addressed concerns related to compliance and the legal challenges associated with the final transparency rule.
This webinar was presented in conjunction with:
Dallas-Fort Worth Hospital Council
Florida Hospital Association
Georgia Hospital Association
Kansas Hospital Association
Louisiana Hospital Association
Montana Hospital Association
Not a surprise to most — healthcare is making headlines on an international level. Though not front and center, still of importance to the hospital community are issues working their way through government agencies and the legislature.
As one of the keynote speakers of this year’s virtual Florida Institute of CPAs Health Care Industry Conference, PYA Senior Manager Kathy Reep presented a “Federal Legislative and Regulatory Update.” She covered a number of current issues affecting healthcare providers, including:
Price transparency.
Congressional action on surprise billing.
The Administration’s budget for 2021.
Medicare proposed rules related to hospital inpatient payments and post-acute care for FY2021.
The virtual event took place June 23-24, 2020.
Webinar: Post-Pandemic Provider Realignment — Navigating An Uncertain MarketPYA, P.C.
The COVID-19 pandemic will materially affect U.S. provider industry structure, as financial weaknesses are exposed, risk tolerances are tested, and uncertainties persist. As a result, provider mergers-and-acquisitions (M&A) activities across industry sectors will likely spike in the short- to medium-term future. Providers of all types need to be aware of, and prepared for, the changes they will face.
In this 45-minute joint webinar, PYA Principal Brian Fuller and Juniper Advisory Managing Director Jordan Shields provided a real-time assessment of the COVID-19 pandemic, as well as shared predictions for what the extending crisis means in coming years for M&A activity in the provider space.
The webinar took place Thursday, August 6, 2020, at 11 a.m. EDT.
Since March, PYA experts have closely tracked and carefully evaluated the pandemic’s impact on employed physician compensation. During this complimentary one-hour webinar, PYA Principals Angie Caldwell and Martie Ross highlighted five immediate considerations for hospitals and health systems to manage the storm. They also explored five longer-term considerations impacting future planning.
This webinar took place Friday, July 24, 2020, at 11 a.m. EDT, and was held in conjunction with:
Dallas-Fort Worth Hospital Council
Florida Hospital Association
Kansas Hospital Association
Montana Hospital Association
The COVID-19 pandemic has exposed organizational and industry weaknesses. To build a more resilient delivery system, leaders now must engage their governing boards in re-calibrating strategic plans, re-evaluating investments, and re-imagining hospitals’ and health systems’ roles in their communities.
In this 45-minute webinar, PYA Principals Martie Ross and Brian Fuller provided a framework for these critical discussions including root-cause analysis, market assessment, new realities, guiding principles, and strategic and operational priorities.
This webinar originally took place on Wednesday, June 24, 2020.
Webinar: Free Money with Strings Attached – Cares Act Considerations for Fron...PYA, P.C.
PYA, in conjunction with the Montana Hospital Association, recently co-hosted a Frontier States Town Hall Meeting webinar, “Free Money With Strings Attached: CARES Act Considerations for Frontier States’ Healthcare Provider Organizations.” Principals Lori Foley, Martie Ross, and David McMillan introduced the CARES Act Provider Relief Fund including distribution formulas, the attestation process, the verification and application process, and ongoing recordkeeping requirement. They also answered attendees’ numerous questions regarding these matters.
Webinar: “Got a Payroll? Don’t Leave Money on the Table”PYA, P.C.
Under the CARES Act, every employer with a payroll has an opportunity to retain cash–whether they have a PPP loan or not. What employers need to know right now.
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) along with the Payroll Protection Program (PPP) offer all business owners relief, but the details can be confusing or overlooked.
Perhaps you don’t fully understand how the deferral of the employer’s share of Social Security taxes works. Maybe you wonder if the deferral even applies to you—good news, it does if you have a payroll!
Failure to fully understand your options could cost you money, at a time when “cash is king.”
As part of PYA’s ongoing commitment to sharing helpful guidance, Tax Principals Debbie Ernsberger and Mark Brumbelow outlined issues and opportunities within the CARES Act, and answered questions during a one-hour webinar that originally aired on Wednesday, May 20, 2020.
Webinar: So You Have a PPP Loan. Now What?PYA, P.C.
The CARES Act provides relief to small businesses through Paycheck Protection Program (PPP) loans, but receiving the loan is only the first part of the equation. PYA discussed what businesses need to know and do next.
Failure to fully understand the requirements for PPP loan forgiveness could cost employers money, at a time when every penny counts. Employers need to stay up-to-date on recent activities regarding the PPP loan forgiveness application, necessary documentation, and other best practices to ensure they are well-prepared for the next steps under the PPP.
As part of PYA’s ongoing commitment to sharing helpful guidance, Tax Principals Debbie Ernsberger and Mark Brumbelow outlined PPP loan forgiveness requirements and answered questions during a one-hour webinar on Wednesday, June 3, 2020.
Webinar: “Making It Work—Physician Compensation During the COVID-19 Pandemic”PYA, P.C.
What to do with your physician compensation plan in the face of the COVID-19 pandemic? It’s a question that leaves administrators searching for answers.
PYA Principal Angie Caldwell and Senior Manager Katie Culver introduced several key considerations for provider compensation during and after the COVID-19 pandemic. In PYA’s complimentary webinar, they:
Summarized the current environment impacting physician compensation associated with the pandemic.
Provided an overview of the Stark Blanket Waivers and opportunities created for physician compensation.
Described restoration and recovery strategies for physician resources.
PYA hosted this one-hour webinar Tuesday, April 28, 2020, at 11 a.m. EDT in conjunction with the Florida Hospital Association.
Webinar: “Hospitals, Capital, and Cashflow Under COVID-19”PYA, P.C.
Hospitals and providers need to think creatively, strategically, and long-term about capital and cashflow under the pressures of the COVID-19 pandemic. A one-hour webinar hosted by PYA discussed the current state of capital markets for non-profit healthcare systems, and considerations for capital management, including the role of real estate assets.
PYA Principal Michael Ramey joined Realty Trust Group Senior Vice-President Michael Honeycutt and Ponder & Company Managing Director Jeffrey B. Sahrbeck to present “Hospitals, Capital, and Cashflow, Under COVID-19” In this webinar, they covered:
Hospital industry capital market updates and trends, including how the capital markets are responding to the crisis.
Access to capital under recent regulations.
Cash preservation techniques for hospitals considering real estate operations and assets.
The webinar took place Thursday, April 9, 2020, at 11 a.m. EDT.
PYA Webinar: “Additional Expansion of Medicare Telehealth Coverage During COV...PYA, P.C.
Late on March 30, CMS released an interim rule which, among other things, significantly expands Medicare telehealth coverage, even beyond the initial Section 1135 waivers. PYA’s complimentary one-hour webinar explained these changes and how they make telehealth an even more attractive option in response to the COVID-19 pandemic.
PYA Principals Martie Ross and Valerie Rock addressed the latest developments, including:
New reimbursement for telephone-only services.
Broader coverage for remote patient monitoring.
New payments for rural health clinics and federally qualified health centers.
Use of telehealth to meet supervision requirements.
New rules regarding coding and billing as well as the changed payment rates for telehealth services.
The webinar took place Friday April 3, 2020, at 11 a.m. EDT.
Webinar: “Getting Online with Telehealth: Practical Guidance for Physician Pr...PYA, P.C.
Medicare’s decision to reimburse for telehealth services, concerns for patient and staff safety, and the loss of revenue from canceled elective procedures are leading many physician practices to consider providing or expanding telehealth services.
During this webinar, PYA’s panel of heavy-hitting experts provided guidance physician practices can use to rollout, or further tap into, the telehealth opportunity. The presenters discussed:
Technology options and speed-to-implementation.
Solutions to internal process challenges.
Patient engagement in telehealth.
PYA hosted this one-hour webinar Thursday, March 26, 2020, at 4 p.m. EDT.
India Clinical Trials Market: Industry Size and Growth Trends [2030] Analyzed...Kumar Satyam
According to TechSci Research report, "India Clinical Trials Market- By Region, Competition, Forecast & Opportunities, 2030F," the India Clinical Trials Market was valued at USD 2.05 billion in 2024 and is projected to grow at a compound annual growth rate (CAGR) of 8.64% through 2030. The market is driven by a variety of factors, making India an attractive destination for pharmaceutical companies and researchers. India's vast and diverse patient population, cost-effective operational environment, and a large pool of skilled medical professionals contribute significantly to the market's growth. Additionally, increasing government support in streamlining regulations and the growing prevalence of lifestyle diseases further propel the clinical trials market.
Growing Prevalence of Lifestyle Diseases
The rising incidence of lifestyle diseases such as diabetes, cardiovascular diseases, and cancer is a major trend driving the clinical trials market in India. These conditions necessitate the development and testing of new treatment methods, creating a robust demand for clinical trials. The increasing burden of these diseases highlights the need for innovative therapies and underscores the importance of India as a key player in global clinical research.
Defecation
Normal defecation begins with movement in the left colon, moving stool toward the anus. When stool reaches the rectum, the distention causes relaxation of the internal sphincter and an awareness of the need to defecate. At the time of defecation, the external sphincter relaxes, and abdominal muscles contract, increasing intrarectal pressure and forcing the stool out
The Valsalva maneuver exerts pressure to expel faeces through a voluntary contraction of the abdominal muscles while maintaining forced expiration against a closed airway. Patients with cardiovascular disease, glaucoma, increased intracranial pressure, or a new surgical wound are at greater risk for cardiac dysrhythmias and elevated blood pressure with the Valsalva maneuver and need to avoid straining to pass the stool.
Normal defecation is painless, resulting in passage of soft, formed stool
CONSTIPATION
Constipation is a symptom, not a disease. Improper diet, reduced fluid intake, lack of exercise, and certain medications can cause constipation. For example, patients receiving opiates for pain after surgery often require a stool softener or laxative to prevent constipation. The signs of constipation include infrequent bowel movements (less than every 3 days), difficulty passing stools, excessive straining, inability to defecate at will, and hard feaces
IMPACTION
Fecal impaction results from unrelieved constipation. It is a collection of hardened feces wedged in the rectum that a person cannot expel. In cases of severe impaction the mass extends up into the sigmoid colon.
DIARRHEA
Diarrhea is an increase in the number of stools and the passage of liquid, unformed feces. It is associated with disorders affecting digestion, absorption, and secretion in the GI tract. Intestinal contents pass through the small and large intestine too quickly to allow for the usual absorption of fluid and nutrients. Irritation within the colon results in increased mucus secretion. As a result, feces become watery, and the patient is unable to control the urge to defecate. Normally an anal bag is safe and effective in long-term treatment of patients with fecal incontinence at home, in hospice, or in the hospital. Fecal incontinence is expensive and a potentially dangerous condition in terms of contamination and risk of skin ulceration
HEMORRHOIDS
Hemorrhoids are dilated, engorged veins in the lining of the rectum. They are either external or internal.
FLATULENCE
As gas accumulates in the lumen of the intestines, the bowel wall stretches and distends (flatulence). It is a common cause of abdominal fullness, pain, and cramping. Normally intestinal gas escapes through the mouth (belching) or the anus (passing of flatus)
FECAL INCONTINENCE
Fecal incontinence is the inability to control passage of feces and gas from the anus. Incontinence harms a patient’s body image
PREPARATION AND GIVING OF LAXATIVESACCORDING TO POTTER AND PERRY,
An enema is the instillation of a solution into the rectum and sig
CRISPR-Cas9, a revolutionary gene-editing tool, holds immense potential to reshape medicine, agriculture, and our understanding of life. But like any powerful tool, it comes with ethical considerations.
Unveiling CRISPR: This naturally occurring bacterial defense system (crRNA & Cas9 protein) fights viruses. Scientists repurposed it for precise gene editing (correction, deletion, insertion) by targeting specific DNA sequences.
The Promise: CRISPR offers exciting possibilities:
Gene Therapy: Correcting genetic diseases like cystic fibrosis.
Agriculture: Engineering crops resistant to pests and harsh environments.
Research: Studying gene function to unlock new knowledge.
The Peril: Ethical concerns demand attention:
Off-target Effects: Unintended DNA edits can have unforeseen consequences.
Eugenics: Misusing CRISPR for designer babies raises social and ethical questions.
Equity: High costs could limit access to this potentially life-saving technology.
The Path Forward: Responsible development is crucial:
International Collaboration: Clear guidelines are needed for research and human trials.
Public Education: Open discussions ensure informed decisions about CRISPR.
Prioritize Safety and Ethics: Safety and ethical principles must be paramount.
CRISPR offers a powerful tool for a better future, but responsible development and addressing ethical concerns are essential. By prioritizing safety, fostering open dialogue, and ensuring equitable access, we can harness CRISPR's power for the benefit of all. (2998 characters)
The Importance of Community Nursing Care.pdfAD Healthcare
NDIS and Community 24/7 Nursing Care is a specific type of support that may be provided under the NDIS for individuals with complex medical needs who require ongoing nursing care in a community setting, such as their home or a supported accommodation facility.
Empowering ACOs: Leveraging Quality Management Tools for MIPS and BeyondHealth Catalyst
Join us as we delve into the crucial realm of quality reporting for MSSP (Medicare Shared Savings Program) Accountable Care Organizations (ACOs).
In this session, we will explore how a robust quality management solution can empower your organization to meet regulatory requirements and improve processes for MIPS reporting and internal quality programs. Learn how our MeasureAble application enables compliance and fosters continuous improvement.
The dimensions of healthcare quality refer to various attributes or aspects that define the standard of healthcare services. These dimensions are used to evaluate, measure, and improve the quality of care provided to patients. A comprehensive understanding of these dimensions ensures that healthcare systems can address various aspects of patient care effectively and holistically. Dimensions of Healthcare Quality and Performance of care include the following; Appropriateness, Availability, Competence, Continuity, Effectiveness, Efficiency, Efficacy, Prevention, Respect and Care, Safety as well as Timeliness.
Health Education on prevention of hypertensionRadhika kulvi
Hypertension is a chronic condition of concern due to its role in the causation of coronary heart diseases. Hypertension is a worldwide epidemic and important risk factor for coronary artery disease, stroke and renal diseases. Blood pressure is the force exerted by the blood against the walls of the blood vessels and is sufficient to maintain tissue perfusion during activity and rest. Hypertension is sustained elevation of BP. In adults, HTN exists when systolic blood pressure is equal to or greater than 140mmHg or diastolic BP is equal to or greater than 90mmHg. The
How to Have a Successful Engagement and a Happily Ever After: “New Age” Nuances to Physician Hospital Arrangements
1. R. Ross Burris, Shareholder
Polsinelli
Tynan P. Olechny, Principal
Valerie G. Rock, Consulting Manager
PYA
How to Have a Successful Engagement and
a Happily Ever After: “New Age” Nuances to
Physician-Hospital Arrangements
HCCA Regional Conference Atlanta 2016
2. Prepared for HCCA Regional Conference Atlanta 2016page | 2
Objectives
Getting Engaged
• Understand common pre-
transaction legal and
regulatory compliance
pitfalls including due-
diligence opportunities
Honeymooning
• Learn to successfully
implement key operational
and compliance success
factors in ongoing
relationship management to
ensure long-term success
Renewing your vows
• Present best practices to
ensure a successful
anniversary, including
critical planning steps and
considerations in contract
renewals
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Getting Engaged
▪ Various ways to get engaged
▪ Numerous legal and regulatory
considerations
▪ Careful planning required
▪ Coding and compliance
considerations
▪ Financial and operational due
diligence
▪ Valuation documentation
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Various Ways to Get Engaged
Independent
Physician and
Independent
Medical Staff
Privileges
Cooperation
through
Professional
Services
Contract
- Medical
Director
- Call
Coverage
- Other
Professional
Services
Direct
Employment
Employment
through
Affiliates
Purchase
Physician
Practice and
Employ
Physicians
Clinical and
Contractual
Joint Ventures
Ambulatory
Surgery Center
Imaging
Modality
PHO
Management
Services
Service Line
Co-
Management
Agreements
CIN
PHO
ACO
5. Prepared for HCCA Regional Conference Atlanta 2016page | 5
Numerous Regulatory and Legal Issues
• State and federal fraud and abuse
• Anti-trust
• Provider-based requirements
• Physician/provider credentialing
• Licensure/CLIA/Pharmacy
• Change of ownership documentation/notification
• Group purchasing organization purchasing/340B pricing
• Commercial reasonableness (i.e., need for services,
financial viability, etc.)
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It’s All About the Plan
Understand the
Complex
Regulatory
Environment
Be Aware of
Recent
Compliance
Trends
Understand the
Forces Driving
Integration
Know the High
Cost of Poor
Planning
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They’re All Watching You
RACs/
ZPICs
State
Legislatures
State AGs
Congress Medicaid
HHS
FTC
FDA
DOJ
Plaintiff
Lawyers
Commercial
Payors
Personal
Injury
Litigants
Competitors
OIG
PRESS
Medicare/CMS
YOU
State
Licensing
Agencies
SEC
Whistle-
blowers
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The Intricate Compliance Web
▪ State and Federal Agencies
▪ Carrying out
▪ State and Federal Laws
▪ In partnership with
▪ Private and Public Organizations
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State and Federal Laws & Regulations
Laws
▪ Affordable Care Act (ACA)
▪ Anti-Kickback Statute (AKS)
▪ Stark Law
▪ Civil Monetary Penalties
(CMP)
▪ False Claims Act (FCA)
▪ Social Security Act (SSA)
▪ HIPAA & HITECH
▪ State Physician Self-Referral
(Baby Stark)
▪ CON
▪ CPOM & Fee Splitting
Regulations
▪ Conditions of Participation
▪ Enrollment & Recertification
▪ Reimbursement
▪ Licensure
▪ Assignment
▪ Suspension and Exclusion
▪ Antitrust
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The Bad Boys of Healthcare Justice -
Ft. Anti-Kickback Statute (AKS)
▪ Prohibits the “knowing” and “willful” offer, payment, solicitation,
receipt or facilitation of remuneration– i.e., both sides of any kickback
▪ Intent Required
▪ “Remuneration” defined broadly as anything of value including cash,
discounts, rebates, and even free goods
▪ Applies to arrangements involving items or services reimbursed in
whole OR in part by a Federal Healthcare Program
▪ Virtually any type of marketing program or marketing relationship with
a physician, long-term care facility, or other provider can implicate the
AKS
▪ Applies to virtually any financial relationship with any party in a
position to refer or recommend business
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AKS (cont.)
▪ Regulated by the Office of Inspector General (OIG) and the
Department of Justice (DOJ)
▪ Criminal + Civil penalties - fines, imprisonment, potential
Medicare/Medicaid exclusion, potential “bootstrapped” False Claims
Act claims:
▪ 5 year prison or $25K per violation
▪ Up to 5-year exclusion
▪ 3x remuneration offered + 50K per violation
▪ “Safe Harbors” are “voluntary,” but if met, immunize the arrangement
from prosecution
▪ "Safe Harbors" are narrowly drawn and there is no "marketing" safe
harbor
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The Bad Boys of Healthcare Justice -
Ft. Physician Self-Referral Act (Stark)
▪ “a physician [or their immediate family member] who has
a direct or indirect financial relationship with [a DHS]
entity, may not make a referral for the furnishing of DHS
for which payment otherwise may be made under
Medicare.”
▪ Strict Liability – NO INTENT REQUIRED
▪ An entity that furnishes DHS pursuant to a prohibited
referral may not present or cause to be presented a claim
or bill to the Medicare program or to any individual, third
party payer, or other entity for the DHS performed
pursuant to the prohibited referral
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Stark (cont.)
▪ DHS is a defined term (e.g., DME equipment and
supplies, home health, prosthetics)
▪ Physician is a defined term
▪ Financial Relationship is…a defined term
▪ ONLY applies to “Physicians” (and those that the
physician deals with) and “Medicare” BUT
▪ Applies to referrals between any third-party DHS entities
AND even the physician’s own practice entity
▪ UNLESS AN EXCEPTION IS MET
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The Bad Boys of Healthcare Justice -
Ft. False Claims Act (FCA)
FCA 101
Treble damages and fines for knowingly:
Filing a false claim with the Federal government, or causing
the filing of a false claim
Creating a false record in order to get a claim paid
Conspiring to get a false claim paid, or
Concealing an obligation to repay monies owed to the
Federal government.
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FCA (cont.)
▪ Bootstrapping to AKS Claims
▪ ACA allows the government to “bootstrap” an FCA claim to an
AKS claim, arguing, in essence that the kickback relationship
made the claim false.
▪ Qui Tam Relators
▪ FCA allows individuals to bring suit against companies as qui tam
relators.
▪ 60-Day Rule
▪ Failing to return “identified” overpayment w/in 60 days.
▪ Bottom Line
▪ Violating AKS, the Stark Law or failing to return overpayments 60
days after identifying may create FCA liability even with an
indirect seller of goods or services.
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The Bad Boys of Healthcare Justice -
Ft. HIPAA & HITECH
▪ The Health Insurance Portability and Accountability Act
(HIPAA) and the related Health Information Technology
for Economic and Clinical Health (HITECH)
▪ HIPAA requires Covered Entities and their Business
Associates to protect Private Health Information (PHI)
▪ HITECH has specific security standards for PHI and
requires mandatory disclosure when a data breach has
occurred
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HIPAA & HITECH (cont.)
▪ Further requirements:
▪ Covered Entities must conduct security assessments to identify
vulnerabilities
▪ Business Associates are also subject to audit & investigation
▪ Covered Entities must report Business Associate breaches of
unsecured PHI
▪ OCR may open a compliance review to investigate any reported
breach of unsecured PHI
▪ Covered Entities have greater liability if Business Associate is
acting as “agent”
▪ Unclear how OCR is interpreting this term
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Careful Planning Required
▪ Initiate confidentiality and non-solicitation agreements
▪ Assemble the “engagement team”
▪ Board of Directors, administration (C-suite), legal, compliance, finance,
operations, human resources
▪ Outside counsel
▪ Appraisers to conduct business and compensation valuations
▪ Execute letter of intent (LOI) or term sheet
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Careful Planning Required (cont.)
▪ Identify assets to be acquired
▪ Permits/licenses/certifications/government approvals
▪ Rights under contracts (vendors, suppliers, software, etc.)
▪ All tangible and personal property (FFE)
▪ Inventories of supplies, purchased goods, drugs, etc.
▪ Intellectual property
▪ Rights under leases
▪ Prepaids; security deposits
▪ Patient records
▪ EHR
▪ Personnel
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Careful Planning Required (cont.)
▪ Other “up front” considerations
▪ Length of agreement
▪ Minimum period of time that party cannot terminate "without cause"
▪ Compensation structure
▪ Minimum guaranteed base salary plus productivity bonus
▪ Compensation or collections/wRVU (for PSA)
▪ Incorporation of quality component
▪ Specific reference to modifier adjusted, personally performed
wRVUs
▪ Consistent compensation terms, subject to existing practice metrics
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Careful Planning Required (cont.)
▪ Other “up front” considerations (cont.)
▪ Inclusion of clause that expects the provider to bill according
to government and commercial payer requirements
▪ Renegotiating leverage tied to individual performance
▪ Compensation at all times must be subject to fair market
value and commercial reasonableness requirements
▪ Include clause for assessing contract if a specific % shift in coding
or wRVU totals occurs from year to year
▪ Any obvious unbundled codes to be excluded at true up
▪ Noncompetes – duration, scope of services, geographic
scope
▪ Unwind provisions
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Coding and Compliance Considerations
▪ Detailed analysis of data and assessment of risk
▪ Internal
▪ External
▪ Anticipate practice changes
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Data Analysis & Risk Assessment: Internal Data
▪ Benchmark:
▪ Evaluation and Management (E/M) services
▪ Procedures (high use of at-risk procedures)
▪ Use of modifiers
▪ wRVUs (productivity)
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Data Analysis & Risk Assessment: External Data
▪ Publically reported data
▪ Highest utilizers of codes or modifiers are targets for audits
▪ OIG, CERT, RAC audit activity; recent CIAs
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Data Analysis and Risk Assessment: Tip
▪ Be careful of exposing issues
▪ Once exposed, issues must be addressed
▪ Ensure due diligence is only as aggressive as the hospital’s ability
to react to potential issues
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Anticipate Practice Changes
▪ Practice pattern changes, once employed, that change
the data
▪ Shift to provider-based
▪ Nonphysician provider (NPP) services/utilization
▪ Shift of ancillary services to the hospital
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Due Diligence
▪ Traditional Purpose: obtain information about what is
material to the Seller’s business and identify items that
may need additional attention and analysis.
▪ Typical requests include information regarding:
• Corporate Documents • Legal Issues and Govt. Investigations
• Accounting and Financial Statements • Licensure and Certifications
• Assets and Liens • Compliance Program and Training
• Material Contracts and Payor
Agreements
• Privacy and Security
• Real Property – Owned/Leased • Employees / Independent
Contractors
• Intellectual Property • Medical Staff
• Insurance • Environmental
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The Due-Diligence Balancing Act
Educate C-Suite on importance of
including compliance ON THE
FRONT END of deals
▪ Have Due-Diligence Plan
▪ Clearly Define Goals
▪ Select tools (interviews, document
review, etc.)
▪ Stay within parameters
▪ 60-Day Rule = Due-Diligence
Balancing Act
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Financial and Operational Due Diligence
▪ Historical compensation
▪ Historical billing and collections activities
▪ Overhead expenses
▪ Staff
▪ Rent
▪ Malpractice insurance
▪ Physician and staff benefits
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Financial and Operational Due Diligence
▪ Staffing complement and ratios
▪ Payer mix
▪ Credentialing considerations
▪ Medicare/Medicaid processing times can be lengthy
▪ Future billing and collection activities
▪ Who will conduct?
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Valuation Documentation
▪ Documenting and validating supporting documentation for
physician compensation
▪ Physician needs assessment
▪ Documenting calculation of designated health services
▪ Be cognizant of any "special" arrangements for physicians
(e.g., anything that differentiates one physician's contract
from the general provisions of other physician contracts)
▪ Obtain fair market valuation opinion to support physician
compensation arrangements
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Finally…
▪ Before closing, prepare a post-closing checklist noting action
items for issues identified during due diligence. Don't let
issues identified during diligence get lost in the shuffle!
▪ Addressing issues as soon after closing as possible assists in
risk reduction.
▪ Compile a post-integration multi-disciplinary team and assign
responsibilities for post-closing projects.
▪ If possible, schedule post-close plan kickoff call and regular
team meetings to discuss the status of post-close projects.
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Honeymooning
▪ Most parties go into the relationship with the
intention of being “in it for the long haul.”
▪ Post-integration process may take longer
than the planning/negotiation, due diligence,
and transaction closing steps combined.
▪ The length and complexity of the post-
integration process will vary depending on the
type of transaction entered.
▪ Thorough due diligence on the front end will
help ensure a carefree honeymoon period.
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Honeymooning “To Dos”
▪ Monitor physician behavior changes
▪ Continually audit, track and communicate
▪ Create or confirm audit and disciplinary policies are clear
and enforcable/enforced
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Wedding Catastrophes
Successor Liability for Overpayments
▪ United States v. Vernon Home Health, Inc., 21 F.3d 693, 5th Cir.
1994 (Nursing home successor liable for predecessor’s
overpayments in asset purchase b/c federal law preempts state
corporate law and provider number was assigned)
Antitrust
▪ Federal Trade Commission v. St. Luke's Health System, Ltd.
Case No. 1:12-CV-00560-BLW and 1:13-CV-00116-BLW (D.
Idaho 2014) (Merger would result in anticompetitive pricing that
could not be overcome by efficiencies and ordered divestiture)
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Wedding Catastrophes
Fraud and Abuse/Physician Compensation and Leasing
Issues
▪ Intermountain Health Care, Inc., Settlement Agreement (2013)
▪ U.S. ex rel. Osheroff v. Tenet Healthcare, Case No. 09-22253-
CIV-HUCK/O'SULLIVAN (S.D. Fla 2013)
▪ U.S. ex rel. Schubert v. All Children's Health System, Inc., Case
No. 8:11-cv-1687-T-27-EAJ (M.D. Fla 2013)
▪ U.S. ex rel. Hector Luque v. Adventist Health, Case No. 2:08-
01272 (E.D. Cal. 2013)
▪ 60-Day Rule
▪ Kane v. Healthfirst Inc. et al. and U.S. v. Continuum Health
Partners Inc. et al., Case No. 1:11-cv-02325, (S.D.N.Y. 2015)
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Triggers for Physician Behavior Changes
▪ Compensation based on wRVUs
▪ Provider education
▪ Changes in what drives the physician’s compensation
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Common Behavior Changes -
Compensation Based on wRVUs
▪ Upcoding E/M services
▪ Unbundling E/M services
▪ Minor vs. major global periods
▪ Unbundling surgeries
▪ Tip:
▪ If billing departments are not monitoring for correct coding, the claim
can be submitted with more codes than are paid or correct
▪ If compliance departments are not monitoring for correct coding
compared to documentation, there is increased risk for overpayment
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Commonly Audited Modifiers
▪ 25 - Separate E/M on the same day as a Minor
Procedure
▪ 57 - Separate E/M on the same day or day before as a
Major Procedure
▪ 58 - Staged or Related Procedure During a Global Period
▪ 59 - Distinct Procedural Service
▪ 78 - Unplanned Return to the OR/Related Procedure
▪ 79 - Unrelated Procedure During the Global Period
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Modifier 25
Modifier 25: Significant, Separately Identifiable E/M
Service by the Same Physician on the Same Day of the
Procedure or Other Service
▪ If a procedure has a global period of 000 or 010 days, it is
defined as a minor surgical procedure
▪ The decision to perform a minor surgical procedure is
included in the payment for the minor procedure and
should NOT be reported separately
▪ If a significant and separately identifiable E/M service is
performed, and it is unrelated to the decision to perform
the procedure, then it can be separately reported
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Time: Risk
▪ Using time as a work-around to documenting
▪ Combining E/M time with the time spent performing other
procedures/services
▪ Psychiatric codes
▪ Not documenting time
▪ Assuming time captured in EHR
▪ Too difficult to keep up with
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Tip
▪ Billing and compliance staff should be educated on:
▪ Place of service requirements
▪ Modifiers to identify provider-based
▪ If a practice is provider-based or just a specific location is
▪ How to bill for NPPs in order to identify personally performed services
vs NPP services and correct billing to Medicare and Medicaid
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Common Behavior Changes:
Provider Education
▪ Education and close monitoring can correct physician coding
to be more accurate which can increase or decrease wRVUs
▪ limited prospective reviews
▪ shadowing
▪ and lots of education initially
▪ limit exposure on new providers
▪ Lack of education and monitoring can lead to physician
manipulation of the system
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Common Behavior Changes:
Changes in What Drives Physician Compensation
▪ Change in practice patterns due to NPPs not being
included in the calculation
▪ Shift in work flow
▪ Tip: Confirm omission of NPP services
▪ Ancillary services no longer directly related
▪ Orders may decrease
▪ Do not forget to include supervision for services for which
physicians can no longer directly bill (e.g., infusion supervision)
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Continually Audit, Monitor and Track
▪ Conduct regular billing and coding audits
▪ How often would we recommend?
▪ Conduct periodic operational assessments to ensure best
practices are in place
▪ Provide feedback to physicians routinely
▪ Production
▪ Quality metrics
▪ Financial performance
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Renew Your Vows
▪ Timing of renewal
▪ Commit to fair market value and
commercial reasonableness
compliance reviews
▪ Special considerations
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When to Renew Your Vows
▪ Conduct thorough review of contracts to identify which
contracts to keep and which contracts to terminate or
renegotiate
▪ Many contracts require 30 to 90 days to terminate without
cause
▪ Plan accordingly especially if anticipating significant changes
to agreement terms, arrangement structures, defined quality
metrics, etc.
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Commit to FMV and CR Reviews
▪ Even if agreement is for multiple years, may still need to
evaluate for compliance with fair market value and
commercial reasonableness
▪ Valuation period may be for only 1 year or 2 years when agreement
is for 3 years
▪ Survey benchmarks and reimbursement changes annually
▪ Quality metrics re-evaluation to ensure robustness
▪ Impacts of behavior changes
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Special Considerations
▪ Administration of contract
▪ Appropriate calculation of wRVUs
▪ Modifier adjusted and personally performed
▪ Bonus calculated based on correct threshold
▪ Achievement of quality metrics appropriately tracked and recorded
▪ Medical director time sheets completed
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Special Considerations
▪ Contract mitigation based on audit results
▪ Compliance rate impact on bonus
▪ Deduction of overpayments to bonus
▪ Need for self-disclosure?
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Questions?
R. Ross Burris, III – rburris@polsinelli.com
Polsinelli, P.C.
(404) 523-6010
www.polsinelli.com
Twitter: @ATLHealthLawyer
Tynan P. Olechny – tolechny@pyapc.com
Valerie G. Rock – vrock@pyapc.com
Pershing Yoakley & Associates, P.C.
(404) 266-9876
www.pyapc.com
Editor's Notes
Mention Medicare Enrollment Certification Statement – Provider states that it is, and will remain, in conformity with all applicable state and federal laws
(d) Reporting and returning of overpayments
(1) In general
If a person has received an overpayment, the
person shall—
(A) report and return the overpayment to
the Secretary, the State, an intermediary, a
carrier, or a contractor, as appropriate, at
the correct address; and
(B) notify the Secretary, State, intermediary,
carrier, or contractor to whom the
overpayment was returned in writing of the
reason for the overpayment.
Write up recent new hire story, contract issues, unbundling, RVUs increase dramatically, billing did not clean the claim, no monitoring
Review guidelines, 58 OR restrictions, etc
59 should not be used to bypass an edit if not supported by med nec and docum
Story, children’s hospital, compliance trying to determine what POS to bill, but unsure of the type of location, how the entity was set up, provider-based, etc