lwconsulting

Understanding Who Is Responsible for Compliance Program Failures

(Hint: It’s You) Let’s be honest with ourselves. For years, many organizations have viewed having a comprehensive compliance program as a “check the box” activity. If there was a binder on the shelf labeled “Compliance Program,” then organizational leadership felt like they were covered. Then, along came the role of Compliance Officer, and it became that person’s issue. Except, the comprehensive compliance program was one problem among many. While the compliance officer was busy putting…

Understanding Assistant-At-Surgery and Co-surgeon Claims

The Office of Inspector General (OIG) recently completed an audit on their workplan of co-surgeon claim payments to determine if the payments complied with federal requirements. Per the OIG, their findings were as follows: “From our 100 statistically sampled services, we found that 69 did not comply with Federal requirements. Specifically, these statistically sampled services included 49 that were incorrectly billed without the co-surgery modifier, 14 that were incorrectly billed without an assistant-at-surgery modifier, and…

Are You Ready for the Inpatient Rehabilitation Review Choice Demonstration (RCD)?

In December 2020, the Centers for Medicare & Medicaid Services (CMS) published a request for comments on the proposed Review Choice Demonstration Project, or RCD for Inpatient Rehabilitation Facilities (IRF). Comments were received, and CMS finalized the plan to roll out this pre-claim or post-payment review. This project was delayed due to the pandemic, however, it was never forgotten by CMS. The rollout in Pennsylvania is scheduled for June 17, 2024! What is the Demonstration…