DOJ and Post-Pandemic Initiatives

This is a great article from Compliance and - be sure your practice/team is reporting services accurately! Beware the Department of Justice’s New Post-Covid Enforcement Priorities

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Reporting Field Avoidance for Anesthesia Care

In the 2019 Relative Value Guide (RVG), published by the American Society of Anesthesiologists (ASA), reporting guidance for field avoidance is clarified. The guide states “Whenever access to the airway is limited (eg, field avoidance), the anesthesia work required may be substantially greater compared to the typical patient.  This anesthesia care has a minimum base unit value of 5 regardless of any lesser base unit value assigned to such procedure in the body of the Relative Value guide. Refer to the text in Modifier 22, page xvi.” As instructed, page xvi – Modifier 22 section reads “22   Increased Procedural Services: When the work required to provide a service is substantially greater than typically required, it may be identified by adding modifier 22 to the usual procedure code. Documentation must support the substantial additional work and the reason for the additional work (ie. Increased intensity, time, technical difficulty of procedure, severity of patient’s condition, physical and mental effort required).…

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New Certification

Soooooo excited to be a Certified Internal Forensic Healthcare Auditor (CIFHA) and member of the American Institute of Healthcare Compliance, Inc. This certification adds a dimension to my professional credentials that will service me well in Compliance investigations, healthcare auditing and assisting my clients in their interview processes.

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OIG Posts Fraud Indicator

Fraud Risk IndicatorOIG assessment of future risk posed by persons who have allegedly engaged in civil healthcare fraud. The government's primary civil tool for addressing healthcare fraud is the False Claims Act (FCA). Most FCA cases are resolved through settlement agreements in which the government alleges fraudulent conduct and the settling parties do not admit liability. Based on the information it gathers in an FCA case, OIG assesses the future trustworthiness of the settling parties (which can be individuals or entities) for purposes of deciding whether to exclude them from the Federal healthcare programs or take other action. OIG applies published criteria to assess future risk and places each party to an FCA settlement into one of five categories on a risk spectrum. OIG uses its exclusion authority differently for parties in each category (as described in the criteria and below). OIG bases its assessment on the information OIG has reviewed in the context of the resolved FCA case and…

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