Medicare Compliance & Reimbursement

Hospitals that "self attest" their provider-based entities could save themselves a bundle if the Centers for Medicare & Medicaid Services later denies their provider-based status. So says CMS in an April 18 program memorandum (A-03-030; http://cms.hhs.gov/manuals/pm_trans/A03030.pdf) that offers an overview of provider-based status rules. The agency says that if it denies provider-based status, it would collect overpayments going back to the submission of the attestation for self-attesting facilities, but would pursue overpayment all the way back to Oct. 1, 2002 for non-self-attesting organizations. In other recent program memoranda, CMS:
urges durable medical equipment regional carriers to insist that physicians use ICD-9-CM codes that provide "the highest degree of accuracy and completeness" (B-03-028; http://cms.hhs.gov/manuals/pm_trans/B03028.pdf); and
clarifies claims processing issues connected with the single drug pricer (AB-03-047; http://cms.hhs.gov/manuals/pm_trans/AB03047.pdf).