Breaking Compliance News Blog

PEPPER Reports Are Coming: Are You Ready?

Posted by Margaret Scavotto, JD, CHC on 4/17/14 3:07 PM

CMS Program for Evaluating Payment Patterns Electronic Reports (PEPPER) reports will be released soon. PEPPER is a Medicare Part A claims data report that compares your SNF to state, national and MAC or FI jurisdiction data. PEPPER includes this comparative data for six Target Areas:

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Topics: PEPPER, Auditing and Monitoring, Billing and Claims Submission

Behind on HIPAA Security? OCR’s new Security Tool raises expectations.

Posted by Margaret Scavotto, JD, CHC on 4/9/14 5:03 PM

The Department of Health & Human Services Office of Civil Rights (OCR), which enforces HIPAA, recently released a Security Risk Assessment (“SRA”) Tool to help providers comply with the HIPAA Security Rule. Security risk assessments are required by the HIPAA Security Rule, and are also required for providers hoping to receive payments through the Meaningful Use Program for EHR.

The HIPAA Security Rule requires covered entities and business associates to assess whether their administrative, physical and technical safeguards sufficiently protect the security of their PHI. The OCR’s SRA Tool, available for download here, walks the user through each safeguard, and is designed to help users assess each security standards and identify remediation needed. The OCR states that the SRA Tool does not transmit user information to the government.

No more excuses!

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Topics: Breaking Compliance News Blog, Auditing and Monitoring, HIPAA

HIPAA Audits Are Coming: Are You Ready?

Posted by Margaret Scavotto, JD, CHC on 3/17/14 4:23 PM

The Department of Health and Human Services (HHS) recently announced that it will conduct a “HIPAA Covered Entity and Business Associate Pre-Audit Survey." It will conduct a survey of 800 covered entities and 400 business associates to determine whether they are appropriate participants for the Office of Civil Rights (OCR) HIPAA Audit Program.

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Topics: Breaking Compliance News Blog, Auditing and Monitoring, HIPAA

PEPPER arrives: Are you an outlier?

Posted by Margaret Scavotto, JD, CHC on 10/3/13 11:57 AM

What is PEPPER?

By now, skilled nursing facilities should have received the CMS Program for Evaluating Payment Patterns Electronic Reports ("PEPPER"). PEPPER is a Medicare Part A claims data report that compares your SNF to aggregated state, national and Medicare Administrative Contractor (MAC) or Fiscal Intermediary (FI) jurisdiction data. PEPPER includes this comparative data for six "Target Areas": 1) Therapy RUGs with high ADLs; 2) Nontherapy RUGs with high ADLs; 3) Change of therapy assessments; 4) Ultrahigh therapy RUGs; 5) Therapy RUGs; and 6) 90+ day episodes of care.

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Topics: PEPPER, Auditing and Monitoring

HIPAA Enforcement Deadline Approaches

Posted by Margaret Scavotto, JD, CHC on 8/30/13 12:02 PM

The enforcement date for the HIPAA Omnibus Final Rule is just around the corner. As September 23 approaches, compliance officers may be wondering if everything is on schedule for completion by the enforcement date.  In HIPAA, we have a hefty set of regulations to guide us in safe, secure management of the health information of those we care for.  Using a well organized, systematic plan for drafting and implementing policies and forms is the best approach to attaining HIPAA compliance.

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Topics: Penalties and Enforcement, Auditing and Monitoring, HIPAA

SNFs Fail to Meet Care and Discharge Planning Requirements

Posted by Andrew Buffenbarger on 3/29/13 10:00 AM

The OIG recently released a review of SNF care and discharge plans. The OIG found that 37% of SNFs did not meet the care planning requirements or did not provide services in accordance with care plans. They go on to say that for 31% of stays, SNFs did not meet discharge planning requirements. The OIG calls for stricter oversight of SNF care and discharge plans as Medicare paid approximately $5.1 billion for stays in which SNFs did not meet the requirements.

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Topics: Penalties and Enforcement, Auditing and Monitoring, Quality Assurance

OIG finds 25% of SNF claims faulty

Posted by Margaret Scavotto, JD, CHC on 11/16/12 3:30 PM

This week, the Office of Inspector General (OIG) released a report: Inappropriate Payments to Skilled Nursing Facilities Cost Medicare More than a Billion Dollars in 2009. The OIG found that 25% of SNF claims submitted in 2009 were in error, amounting to $1.5 billion in overpayments. To read the full report, click here.

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Topics: Compliance Basics, Auditing and Monitoring, Billing and Claims Submission, medical necessity

Compliance program check up: How do you know your billing is accurate?

Posted by Margaret Scavotto, JD, CHC on 6/8/12 2:40 PM

Every health care provider's compliance program should include policies and procedures for complying with the billing requirements of Medicare, Medicaid, and other payors. Undetected billing errors can lead to penalties under the False Claims Act, and/or hefty repayments to the government.
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Topics: Auditing and Monitoring, Billing and Claims Submission

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