No Time Like the Present
It's July, and Congress is knee-deep in its consideration of Medicare reform provisions and development of a Medicare prescription drug benefit. With
Author
Cara C. Bachenheimer, Esq.
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Proceed with Caution
The Office of Inspector General in April issued a Special Advisory Bulletin about joint-venture arrangements between mail-order pharmacies and home medical -
Legislation & Regulation
HIPAA, The Sequel
It’s April 2003, the month that those of us in the health care industry — some of us, anyway — have been counting down to for more two years. The definitive April 14, 2003, deadline has arrived for home care providers, insurance companies and other health care providers to be in compliance with the new federal Health Insurance Portability and Accountability Act privacy rules. By now your organization should have developed and implemented HIPAA privacy-specific policies and procedures that describe how you maintain the confidentiality of protected health information, or PHI. Additionally, you should have trained your employees on those policies and procedures. Finally, you should have begun providing your organization’s Notice of Privacy Practices to new patients. For those of you who have completed... -
CMS/Medicare
Balancing Act
Last year, the four durable medical equipment regional carriers issued supplier-manual updates requiring home medical equipment suppliers, in certain circumstances such as pre-and post-pay audits, to submit physician progress notes to substantiate medical necessity for a particular claim. Then, in December, the Centers for Medicare and Medicaid Services, in its certificate of medical necessity submission to the White House’s Office of Management and Budget, reported “suppliers and physicians will complete these [CMN] forms and as needed supply additional routine supporting documentation necessary to process claims.” To put it plainly, CMS and the DMERCs have placed the burden on DME suppliers to provide to the DMERCs copies of physician progress notes to determine whether the medical necessity criteria were met for a particular claim. The CMN... -
CMS/Medicare
IR 101
The Centers for Medicare and Medicaid Services Dec. 13, 2002, issued a long-awaited interim final rule concerning the application of “inherent reasonableness” to certain Medicare Part B items and services. This expedited IR authority could have an immediate and potentially devastating impact on home medical equipment providers, because the durable medical equipment regional carriers now have the ability to reduce payments for durable medical equipment, prosthetics and orthotics at a faster pace. Effective Feb. 11, 2003, the regulations explain the process whereby CMS and Medicare carriers — including the DMERCs — will reduce or increase payment amounts when the federal government believes the existing payment amounts are either grossly excessive or grossly deficient. CMS issued the rule as an “interim final rule,” because the agency... -
Operations
New Year’s Resolutions
In the spirit of the New Year, it's time to make some resolutions. Without further ado, let's resolve to: Lobby Your Congressmen Whether or not lawmakers