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Understanding the Difference Between State and Federal Exclusion Check Requirements

Is your organization conducting exclusion checks to support your compliance program? Running monthly exclusion checks helps your organization support your compliance program by ensuring your organization is not employing excluded individuals or partnering with vendors or businesses that are excluded. Not conducting exclusion checks puts your organization at risk of fines and sanction from participating in State and Federal programs. If you are unsure about who has to comply or the background of this mandate,…

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…