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Showing 2 posts from February 2012.

ON THE ENFORCEMENT RADAR: MEDICAID AUDITS AND THE 2012 OIG WORK PLAN

Unlike the Department of Health and Human Services Office of Inspector General (“OIG”) which publishes a Work Plan each year, the Department of Medicaid Services (“Medicaid”) generally does not publish guidance on the areas which it plans to investigate and/or audit. In fact, Medicaid’s website states … “Medicaid does not provide guidance on how companies should bill for services, but will direct you to applicable regulations.  If you receive direction from staff about how to bill, the Department will not be bound by such instruction, unless it was given by a Director or Commissioner.” Because the federal integrity programs are now moving through the process, Kentucky Medicaid providers are starting to see lots of audit activities. Unlike the OIG audits, we don’t know the precise subject matter of the Medicaid audits, but the process for appeal is outlined below in addition to the areas announced for review by the OIG. More >

The Physician Employment Trend Continues

As healthcare reform continues to be implemented, the trend toward clinical integration and consolidation also continues and will be a defining characteristic of healthcare delivery in the years ahead.  One critical component of clinical integration and consolidation has been health systems employing physicians to form large multi-specialty groups to serve the patient population.  Physicians contemplating entering into an employment relationship with a hospital or health system must examine a number of critical issues before entering into an employment agreement. More >

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