In 2015, ProviderTrust created CHIRP - the Compliance Healthcare Index Report - to raise awareness of the potential risk to healthcare organizations who do not comply with regulations regarding employment practices. Since then, "CHIRP has been relied upon by many in the healthcare compliance industry as the "go-to" source for all things exclusion data related," says ProviderTrust co-founder Michael Rosen.
And just like a happy bird outside your window on a nice summer evening (we could use that visual after last weeks' EPIC snowstorm), we hope it will awaken you and draw attention to the depths of data available to help your organization stay compliant.
CHIRP identifies where there are gaps in public records that can be misleading or even result in possible exposure to liability. CMS programs (Medicare, Medicaid, TriCare and CHIPS) will not provide reimbursement for facilities that employ any excluded individuals or companies that are found in national and state exclusion databases.
We all know what doctors are and that they have to be licensed to practice medicine. But what is a POD and what do they have to do with doctors?
A POD stands for Physician Owned Distributorship. An example of a POD could be a medical device distributorship of hip replacements, heart pace makers or other devices. The distributorship is owned by a group of physicians and those physicians can order or determine which supplier/device is inserted or purchased for part of the medical treatment provided by the physician. Hence, the need to know if a hospital employed physician is an owner of a POD is critical in order to avoid possible STARK law violations and for transparency, according to the OIG.
According to the OIG, it is not always clear which doctors have ownership interests in both PODS and the hospitals they sell the devices.Read More
Under 42 C.F.R. § 424.535(a)(12), CMS may revoke the privileges of a supplier if the supplier's Medicaid billing privileges are revoked or terminated by a state Medicaid agency and the supplier has exhausted all applicable appeal rights.In a recent case, Igor Persidsky, M.D./House Calls Medical Corporation v. CMS (2015 BL 350880, HHS Departmental Appeals Bd., Civil Remedies Div. , Dec. No. CR4309, 10/13/15) the Administrative Law Judge held that the deactivation of Dr. Persidsky's billing privileges was essentially the same in effect as a termination or revocation of billing privileges because it was an action that prohibited the supplier from billing Medi-Cal. Read More
Culture comes from the top in a healthy compliance oriented health care company. The OIG is serious about enforcing its prohibition of having federal health care dollars flowing to individuals or entities that have committed healthcare fraud and abuse.
How high up the ladder can the OIG go to make their point?
All the way to the boss.Read More