AHLA. E. My Vendor Made Me Do It: New Compliace Risks in EHR

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "AHLA. E. My Vendor Made Me Do It: New Compliace Risks in EHR"

Transcription

1 AHLA E. My Vendor Made Me Do It: New Compliace Risks in EHR James Cannatti Office of Counsel to the Inspector General US Department of Health and Human Services Washington, DC Danielle B. Fletcher Office of Inspector General US Department of Health and Human Services Washington, DC Robert G. Homchick Davis Wright Tremaine LLP Seattle, WA Current HIT Challenges: mhealth, Big Data, and HIPAA Compliance March 28, 2014

2 My Vendor Made Me Do It: New Compliance Risks in EHRs EHR James A. Cannatti III, Senior Counsel HHS Office of Inspector General Danielle Fletcher, HHS Office of Inspector General Robert G. Homchick, Davis Wright Tremaine, LLP Robert G. Homchick Davis Wright Tremaine, LLP

3 Electronic Medical Records = Sliced Bread Since the days of George W. Bush the federal government has been promoting the adoption of electronic medical records 2006 after prompting by Congress, OIG and CMS publish Stark Exceptions and AKS safe harbors for EMR donations The exceptions/safe harbors were to expire in 2013 but the agencies pushed out the sunset provisions to 2021 Meaningful Use Funding EMRs viewed as essential to improving the coordination of care and reducing costs $17 Billion by the end of 2013 ACOs and other Clinically Integrated Networks strongly encouraged to get wired EMR = Burnt Toast? What Happened? 2

4 EHR My Vendor Made Me Do It? Cloning? Cut & Paste? Audit Logs? Are these real problems? Or the inevitable result of using EMRs? EHR Promotes Fraud? Really? Statements of CMS and OIG Meaningful Use Audits RACs, ZPICs and other Contractors What is happening on the ground when an EMR is implemented? Are Providers using cut and paste indiscriminately? Is this just another way for the RACs to make money? Danielle Fletcher U.S. Department of Health and Human Services Office of Inspector General Office of Evaluations and Inspections

5 Data Sources: Hospital questionnaire of hospitals that received incentive payments Hospital site visits CMS contractor interviews EHR vendor interviews Document review Findings Audit logs User authorization and access controls Data transfer safeguards Patient involvement in anti fraud efforts Copy & paste 4

6 Hospitals Control Over Audit Logs 100% record the date, time and user identification 99% record each entry or access to EHR 99% record each modification to EHR 92% record each signature event Audit logs 44% can delete their audit logs 33% can disable their audit logs 11% can edit their audit logs 5

7 Other Safeguards All hospitals authenticate EHR users (Tokens, PKI, biometrics) 88% of hospitals have limits of data transfer 43% of hospitals include patient involvement in anti fraud efforts 24% of hospitals have copy paste policies CMS and its contractors had adopted few program integrity practices around EHRs Few contractors reviewing EHRs differently than paper medical records Not all contractors can identify copied language or over documentation 6

8 Recommendations: Audit logs operational whenever EHR technology available for updates/viewing ONC and CMS strengthen collaborative efforts CMS develop guidance on use of copy paste CMS provide guidance on fraud/ehrs CMS direct contractors to use providers audit logs s Not All Recommended Fraud Safeguards Have Been Implemented in Hospital EHR Technology asp CMS and Its Contractors Have Adopted Few Program Integrity Practices to Address Vulnerabilities in EHRs asp 7

9 James A. Cannatti III Senior Counsel U.S. Department of Health and Human Services Office of Inspector General Office of Counsel to the Inspector General Documentation and the Importance of Data Accuracy 8

10 Compliance Considerations Questions? 9

Federal Fraud and Abuse Laws

Federal Fraud and Abuse Laws Federal Fraud and Abuse Laws Remaining in Compliance while Attesting to Meaningful Use 1 Overview This presentation provides an overview of key Federal laws aimed at preventing healthcare fraud and abuse

More information

CMS AND ITS CONTRACTORS HAVE ADOPTED FEW PROGRAM INTEGRITY PRACTICES TO ADDRESS VULNERABILITIES IN EHRS

CMS AND ITS CONTRACTORS HAVE ADOPTED FEW PROGRAM INTEGRITY PRACTICES TO ADDRESS VULNERABILITIES IN EHRS Department of Health and Human Services OFFICE OF INSPECTOR GENERAL CMS AND ITS CONTRACTORS HAVE ADOPTED FEW PROGRAM INTEGRITY PRACTICES TO ADDRESS VULNERABILITIES IN EHRS Daniel R. Levinson Inspector

More information

NOT ALL RECOMMENDED FRAUD SAFEGUARDS HAVE BEEN IMPLEMENTED IN HOSPITAL EHR TECHNOLOGY

NOT ALL RECOMMENDED FRAUD SAFEGUARDS HAVE BEEN IMPLEMENTED IN HOSPITAL EHR TECHNOLOGY Department of Health and Human Services OFFICE OF INSPECTOR GENERAL NOT ALL RECOMMENDED FRAUD SAFEGUARDS HAVE BEEN IMPLEMENTED IN HOSPITAL EHR TECHNOLOGY Daniel R. Levinson Inspector General December 2013

More information

Hospital Certified Electronic Health Record (EHR) Technology Questionnaire

Hospital Certified Electronic Health Record (EHR) Technology Questionnaire Page 1 of 10 Hospital Certified Electronic Health Record (EHR) Technology Questionnaire Thank you for taking time to complete this questionnaire. The Office of Inspector General (OIG) is conducting this

More information

Fraud & Abuse Waivers Under the Medicare Shared Savings Program

Fraud & Abuse Waivers Under the Medicare Shared Savings Program Fraud & Abuse Waivers Under the Medicare Shared Savings Program Robert G. Homchick Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

MEDITECH CUSTOMERS & THE OIG QUESTIONNAIRE

MEDITECH CUSTOMERS & THE OIG QUESTIONNAIRE MEDITECH CUSTOMERS & THE OIG QUESTIONNAIRE Hospitals that have received Medicare incentive payments for meaningful use of electronic health records have been asked by the Office of Inspector General of

More information

Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options

Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options Robert G. Homchick Davis Wright Tremaine LLP Arthur N. Lerner Crowell & Moring LLP Shared Savings Program: ACOs Medicare

More information

Navigating Compliance Landmines in EHR Documentation

Navigating Compliance Landmines in EHR Documentation Navigating Compliance Landmines in EHR Documentation Brian T. Bates, CPA, CHC, Mac Corporate Compliance Officer University of Alabama Health Services Foundation, P.C. DISCLAIMER: The views and opinions

More information

Your responses will be saved every time you click the NEXT button.

Your responses will be saved every time you click the NEXT button. Hospital Certified Electronic Health Record (EHR) Technology Questionnaire Thank you for taking time to complete this questionnaire The Office of Inspector General (OIG) is conducting this survey as part

More information

Navigating Compliance Landmines in Electronic Health Record (EHR) Documentation

Navigating Compliance Landmines in Electronic Health Record (EHR) Documentation Navigating Compliance Landmines in Electronic Health Record (EHR) Documentation Brian T. Bates, CPA, CHC, MAc Corporate Compliance Officer University of Alabama Health Services Foundation, P.C. AHLA/HCCA

More information

ACOs: Fraud & Abuse Waivers and Analysis

ACOs: Fraud & Abuse Waivers and Analysis ACOs: Fraud & Abuse Waivers and Analysis Robert G. Homchick and Sarah Fallows Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

Regulatory Compliance Tools from Strategic Management Services March 27, 2012

Regulatory Compliance Tools from Strategic Management Services March 27, 2012 Streamlining Assessments with Regulatory Compliance Tools from Strategic Management Services March 27, 2012 Presented by: Scott Shepherd, SAI Global Compliance 360 GRC Software Suite Camella Boateng, Strategic

More information

OIG Security Audits of EHR Incentive Program Participants

OIG Security Audits of EHR Incentive Program Participants OIG Security Audits of EHR Incentive Program Participants April 12-16, 2015 David G. Schoolcraft and Elana R. Zana Attorneys Ogden Murphy Wallace, P.L.L.C. 1 DISCLAIMER: The views and opinions expressed

More information

EHR s-new Opportunities for the Confident Coder

EHR s-new Opportunities for the Confident Coder EHR s-new Opportunities for the Confident Coder Angela Jordan, CPC Chair AAPCCA Board of Directors Manager Coding and Compliance EvolveMD amjordan.cpc@gmail.com Objective EHR basics Basic knowledge of

More information

ReedSmith. CMS and the OIG Extend Protections for Electronic Health Record Donations. Client Alert. Life Sciences Health Industry Group

ReedSmith. CMS and the OIG Extend Protections for Electronic Health Record Donations. Client Alert. Life Sciences Health Industry Group The business of relationships. SM SM Client Alert Life Sciences Health Industry Group CMS and the OIG Extend Protections for Electronic Health Record Donations Written by Robert J. Hill, Susan A. Edwards

More information

Don t Panic! Surviving a Meaningful Use Audit October, 2014

Don t Panic! Surviving a Meaningful Use Audit October, 2014 Don t Panic! Surviving a Meaningful Use Audit October, 2014 Angie Falletti, RN, PMP Senior Consultant, Encore, A Quintiles Company DISCLAIMER: The views and opinions expressed in this presentation are

More information

Asignificant development among hospitals, physicians,

Asignificant development among hospitals, physicians, : Addressing Tax and Compliance Issues Posed by Electronic Health Systems Recent Developments Highlight Complexity of Tax and Compliance Consequences Ralph Levy, Jr. Ralph Levy, Jr. is of counsel in Nashville,

More information

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program IMPLEMENTING COMPLIANCE PROGRAMS FOR ACCOUNTABLE CARE ORGANIZATIONS Amy K. Fehn I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program The Medicare Shared Savings Program

More information

January 14, 2011. Dear Chairman Issa:

January 14, 2011. Dear Chairman Issa: The Honorable Darrell Issa Chairman Committee on Oversight and Government Reform U.S. House of Representatives 2157 Rayburn House Office Building Washington, D.C. 20515 Dear Chairman Issa: On behalf of

More information

AHLA. B. HIPAA Compliance Audits. Marti Arvin Chief Compliance Officer UCLA Health System and David Geffen School of Medicine Los Angeles, CA

AHLA. B. HIPAA Compliance Audits. Marti Arvin Chief Compliance Officer UCLA Health System and David Geffen School of Medicine Los Angeles, CA AHLA B. HIPAA Compliance Audits Marti Arvin Chief Compliance Officer UCLA Health System and David Geffen School of Medicine Los Angeles, CA Anna C. Watterson Davis Wright Tremaine LLP Washington, DC Fraud

More information

EHRs in 2013: A Holistic View of Issues Facing Providers Wednesday, May 15, 2013

EHRs in 2013: A Holistic View of Issues Facing Providers Wednesday, May 15, 2013 Attorney Advertising Prior results do not guarantee a similar outcome Models used are not clients but may be representative of clients 321 N. Clark Street, Suite 2800, Chicago, IL 60654 312.832.4500 EHRs

More information

Memorandum. ACTION: Report on Computer Security Controls of Financial Management System, FTA FE-2000-098. May 23, 2000.

Memorandum. ACTION: Report on Computer Security Controls of Financial Management System, FTA FE-2000-098. May 23, 2000. U.S. Department of Transportation Office of the Secretary of Transportation Office of Inspector General Memorandum ACTION: Report on Computer Security Controls of Financial Management System, FTA FE-2000-098

More information

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs)

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) By: Chris Rossman, Foley & Lardner LLP, Detroit, Michigan 1. The Centers for Medicare and Medicaid Services ( CMS ) and the Office

More information

THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA

THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA Department of Health and Human Services OFFICE OF INSPECTOR GENERAL THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA BY IMPROVING ITS

More information

Electronic Health Records: Issues, Concerns, and Best Practices

Electronic Health Records: Issues, Concerns, and Best Practices Electronic Health Records: Issues, Concerns, and Best Practices Financial Disclosures Paul Larson is a Senior Consultant with Corcoran Consulting Group. He acknowledges a financial interest in the subject

More information

THE OFFICE OF THE NATIONAL COORDINATOR FOR HEALTH INFORMATION TECHNOLOGY S OVERSIGHT OF THE TESTING

THE OFFICE OF THE NATIONAL COORDINATOR FOR HEALTH INFORMATION TECHNOLOGY S OVERSIGHT OF THE TESTING Department of Health and Human Services OFFICE OF INSPECTOR GENERAL THE OFFICE OF THE NATIONAL COORDINATOR FOR HEALTH INFORMATION TECHNOLOGY S OVERSIGHT OF THE TESTING AND CERTIFICATION OF ELECTRONIC HEALTH

More information

Adopting Electronic Medical Records: What Do the New Federal Incentives Mean to Your Individual Physician Practice?

Adopting Electronic Medical Records: What Do the New Federal Incentives Mean to Your Individual Physician Practice? Adopting Electronic Medical Records: What Do the New Federal Incentives Mean to Your Individual Physician Practice? U John M. Neclerio, Esq.,* Kathleen Cheney, Esq., C. Mitchell Goldman, Esq., and Lisa

More information

MEDICARE S NATIONAL CORRECT CODING INITIATIVE

MEDICARE S NATIONAL CORRECT CODING INITIATIVE Department of Health and Human Services OFFICE OF INSPECTOR GENERAL MEDICARE S NATIONAL CORRECT CODING INITIATIVE INSPECTOR GENERAL SEPTEMBER 2003 OEI-03-02-00770 Office of Inspector General http://oig.hhs.gov

More information

Preparing for HIPAA and Meaningful Use Compliance Audits

Preparing for HIPAA and Meaningful Use Compliance Audits Preparing for HIPAA and Meaningful Use Compliance Audits Presented by: David Holtzman VP of Compliance, CynergisTek CynergisTek, Inc. 11410 Jollyville Road, Suite 2201, Austin TX 78759 512.402.8550 info@cynergistek.com

More information

Stark and Anti-kickback Regulations: Proposed Changes for E-prescribing and Electronic Health Records

Stark and Anti-kickback Regulations: Proposed Changes for E-prescribing and Electronic Health Records Regulatory Advisory This Regulatory Advisory, a special service to America s hospitals, contains guidance about physician self-referral and anti-kickback regulations. Stark and Anti-kickback Regulations:

More information

DEA's New Proposed Regulations For E-Prescribing

DEA's New Proposed Regulations For E-Prescribing Portfolio Media, Inc. 648 Broadway, Suite 200 New York, NY 10012 www.law360.com Phone: +1 212 537 6331 Fax: +1 212 537 6371 customerservice@portfoliomedia.com DEA's New Proposed Regulations For E-Prescribing

More information

Electronic Medical Records 2009 Update and Discussion Forum. Thomas Mohr, D.O., FACOI Rocky Vista University College of Osteopathic Medicine

Electronic Medical Records 2009 Update and Discussion Forum. Thomas Mohr, D.O., FACOI Rocky Vista University College of Osteopathic Medicine Electronic Medical Records 2009 Update and Discussion Forum Thomas Mohr, D.O., FACOI Rocky Vista University College of Osteopathic Medicine Objectives Briefly discuss new legislation concerning electronic

More information

Fraud Prevention in an Increasingly Digitized World

Fraud Prevention in an Increasingly Digitized World Fraud Prevention in an Increasingly Digitized World California Association of Health Plans July 22, 2013 Presented by R. Gregory Cochran, MD, JD Introduction Government s evolving stance on EHR 2004 State

More information

Department of Health and Human Services OFFICE OF INSPECTOR GENERAL

Department of Health and Human Services OFFICE OF INSPECTOR GENERAL Department of Health and Human Services OFFICE OF INSPECTOR GENERAL THE CENTERS FOR MEDICARE & MEDICAID SERVICES IMPLEMENTATION OF SECURITY CONTROLS OVER THE MULTIDIMENSIONAL INSURANCE DATA ANALYTICS SYSTEM

More information

Rebecca Williams, RN, JD Partner Co-chair Health Information Technology/HIPAA Practice Davis Wright Tremaine LLP beckywilliams@dwt.

Rebecca Williams, RN, JD Partner Co-chair Health Information Technology/HIPAA Practice Davis Wright Tremaine LLP beckywilliams@dwt. National EHR Acquisition, Implementation and Operations Summit Rebecca Williams, RN, JD Partner Co-chair Health Information Technology/HIPAA Practice Davis Wright Tremaine LLP beckywilliams@dwt.com Window

More information

2/9/2012. 2012 HIPAA Privacy and Security Audit Readiness. Table of contents

2/9/2012. 2012 HIPAA Privacy and Security Audit Readiness. Table of contents 2012 HIPAA Privacy and Security Audit Readiness Mark M. Johnson National HIPAA Services Director Table of contents Page Background 2 Regulatory Background and HITECH Impacts 3 Office of Civil Rights (OCR)

More information

In early April, the Center for Medicare and Medicaid Services (CMS) issued

In early April, the Center for Medicare and Medicaid Services (CMS) issued April 26, 2011 If you have any questions regarding the matters discussed in this memorandum, please contact the following attorneys or call your regular Skadden contact. John T. Bentivoglio 202.371.7560

More information

INFORMATION SECURITY AT THE HEALTH RESOURCES AND SERVICES ADMINISTRATION NEEDS IMPROVEMENT BECAUSE CONTROLS WERE NOT FULLY IMPLEMENTED AND MONITORED

INFORMATION SECURITY AT THE HEALTH RESOURCES AND SERVICES ADMINISTRATION NEEDS IMPROVEMENT BECAUSE CONTROLS WERE NOT FULLY IMPLEMENTED AND MONITORED Department of Health and Human Services OFFICE OF INSPECTOR GENERAL INFORMATION SECURITY AT THE HEALTH RESOURCES AND SERVICES ADMINISTRATION NEEDS IMPROVEMENT BECAUSE CONTROLS WERE NOT FULLY IMPLEMENTED

More information

Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq.

Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. November 11, 2014 Shipman & Goodwin LLP 2014. All rights reserved. HARTFORD STAMFORD

More information

A smarter way to protect your brand. Copyright 2012 Compliance 360 All Rights Reserved

A smarter way to protect your brand. Copyright 2012 Compliance 360 All Rights Reserved A smarter way to protect your brand Minimizing Compliance Risks of Proactive OCR HIPAA Audits Copyright 2012 Compliance 360 All Rights Reserved Compliance 360 at a Glance Compliance, Risk and Audit Solutions

More information

5/11/2015 AGENDA ROUNDTABLE PARTICIPANTS TALES FROM THE FRONTLINES OF MEANINGFUL USE: FOCUS ON OPTOMETRY

5/11/2015 AGENDA ROUNDTABLE PARTICIPANTS TALES FROM THE FRONTLINES OF MEANINGFUL USE: FOCUS ON OPTOMETRY TALES FROM THE FRONTLINES OF MEANINGFUL USE: FOCUS ON OPTOMETRY Best Practices, Lessons Learned and the Road Ahead June 25, 2015 The CMS EHR Meaningful Use program brings special challenges to the field

More information

,2 2 2009 MAY. oß.vi.. Daniel R. Levinson ~ ~ .~~.vi...

,2 2 2009 MAY. oß.vi.. Daniel R. Levinson ~ ~ .~~.vi... (?.,,,-l'''4,,"vicø -r..'..ll'..410 DEPARTMENT OF HEALTH &. HUMAN SERVICES Office of Inspector General Washington, D.C. 20201 MAY,2 2 2009 TO: James Scanlon Acting Assistant Secretary for Planning Planing

More information

OIG Security Audit: What You Need To Know

OIG Security Audit: What You Need To Know Watch the Replay on YouTube OIG Security Audit: What You Need To Know Executive Series Webinar July 23rd, 2015 Today s Speakers Elana R. Zana Attorney & Author Ogden Murphy Wallace P.L.L.C. ezana@omwlaw.com

More information

Art Gross President & CEO HIPAA Secure Now! How to Prepare for the 2015 HIPAA Audits and Avoid Data Breaches

Art Gross President & CEO HIPAA Secure Now! How to Prepare for the 2015 HIPAA Audits and Avoid Data Breaches Art Gross President & CEO HIPAA Secure Now! How to Prepare for the 2015 HIPAA Audits and Avoid Data Breaches Speakers Phillip Long CEO at Business Information Solutions Art Gross President & CEO of HIPAA

More information

SEP f 1 2006. Nationwide Review of Inpatient Rehabilitation Facilities' Compliance With Medicare's Transfer Regulation (A-04-04-00008)

SEP f 1 2006. Nationwide Review of Inpatient Rehabilitation Facilities' Compliance With Medicare's Transfer Regulation (A-04-04-00008) {42 + STRVLVICEI DEPARTMENT E %*~UV,~~ OF HE&WH & HUMAN SERVICES Office of Inspector General SEP f 1 2006 Washington, D.C. 20201 TO: FROM: SUBJECT: Mark B. McClellan, M.D., Ph.D. Administrator Centers

More information

What is fraud and abuse?

What is fraud and abuse? Medicaid Cost Containment: Combatting Fraud & Abuse What is fraud and abuse? $22 Billion: Medicaid improper payments FY2011 Fraud: misrepresentation of services rendered Abuse: practices that, either directly

More information

Nationwide Review of CMS s HIPAA Oversight. Brian C. Johnson, CPA, CISA. Wednesday, January 19, 2011

Nationwide Review of CMS s HIPAA Oversight. Brian C. Johnson, CPA, CISA. Wednesday, January 19, 2011 Nationwide Review of CMS s HIPAA Oversight Brian C. Johnson, CPA, CISA Wednesday, January 19, 2011 1 WHAT I DO Manage Region IV IT Audit and Advance Audit Technique Staff (AATS) IT Audit consists of 8

More information

Negotiating EHR Acquisition Contracts

Negotiating EHR Acquisition Contracts Negotiating EHR Acquisition Contracts Key Strategies, Terms and Conditions Louisa Barash, Esq. & Jane Eckels, Esq. The Art and Skill of Negotiations Painful Contract Negotiations Take too long Are too

More information

04/03/2015. EMR Documentation and Compliance: The Retina Point of View. Financial Disclosure. Financial Disclosure

04/03/2015. EMR Documentation and Compliance: The Retina Point of View. Financial Disclosure. Financial Disclosure EMR Documentation and Compliance: The Retina Point of View William T. Koch, COA, COE, CPC The Retina Institute Kirk A. Mack, COMT, COE, CPC, CPMA Corcoran Consulting Group Financial Disclosure William

More information

EMR and Meaningful Use. How to Prepare for Audits and Avoid Penalties

EMR and Meaningful Use. How to Prepare for Audits and Avoid Penalties EMR and Meaningful Use How to Prepare for Audits and Avoid Penalties Payment Adjustments for Eligible Professionals who are not Users of Certified Electronic Health Records (EHR) Technology Off-Label Use

More information

MORRISTOWN MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR

MORRISTOWN MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR Department of Health and Human Services OFFICE OF INSPECTOR GENERAL MORRISTOWN MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR Inquiries about this report may be addressed

More information

June 10, 2013. Centers for Medicare & Medicaid Services Department of Health and Human Services 7500 Security Boulevard Baltimore, MD 21244-1850

June 10, 2013. Centers for Medicare & Medicaid Services Department of Health and Human Services 7500 Security Boulevard Baltimore, MD 21244-1850 June 10, 2013 Centers for Medicare & Medicaid Services Department of Health and Human Services 7500 Security Boulevard Baltimore, MD 21244-1850 Subject: (CMS-1454-P; 78 FR 2 1308) Medicare Program; Physicians'

More information

U.S. SECURITIES & EXCHANGE COMMISSION

U.S. SECURITIES & EXCHANGE COMMISSION PBX and Analog Lines Security Assessment U.S. SECURITIES & EXCHANGE COMMISSION March 31, 2000 Prepared by Deloitte & Touche LLP Enterprise Risk Services - 1 - 1 Executive Summary 1.1 Overview Deloitte

More information

SELF AUDITS AND DISCLOSURES IN A RAC WORLD. Kathleen Houston Drummy Partner Davis Wright Tremaine LLP Los Angeles, CA

SELF AUDITS AND DISCLOSURES IN A RAC WORLD. Kathleen Houston Drummy Partner Davis Wright Tremaine LLP Los Angeles, CA SELF AUDITS AND DISCLOSURES IN A RAC WORLD Kathleen Houston Drummy Partner Davis Wright Tremaine LLP Los Angeles, CA 1 Broader Program Integrity Landscape Improper Payments As a result of error As a result

More information

Developing HIPAA Security Compliance. Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant

Developing HIPAA Security Compliance. Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant Developing HIPAA Security Compliance Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant Learning Objectives Identify elements of a HIPAA Security compliance program Learn the HIPAA Security Rule basics

More information

29 OIG 2014 Work Plan explores new compliance projects: Part 2. Nathaniel Lacktman

29 OIG 2014 Work Plan explores new compliance projects: Part 2. Nathaniel Lacktman Compliance TODAY May 2014 a publication of the health care compliance association www.hcca-info.org A unique dual role Indiana s OIG successfully combines statutory law enforcement with Code of Ethics

More information

Mitigating Coding Risks. Concerns with electronic records and overcoding. Balancing Medical Necessity and Meaningful Use 2/20/2014

Mitigating Coding Risks. Concerns with electronic records and overcoding. Balancing Medical Necessity and Meaningful Use 2/20/2014 in the EHR Sandy Giangreco, RHIT, CCS, RCC, CPC, CPC H, CPC I, COBGC, PCS Senior Consultant The Haugen Consulting Group Kim Huey, MJ, CPC, CCS P, PCS, CPCO KGG Coding and Reimbursement Consulting, LLC

More information

11/5/2010. Mara Robertson Tennessee Primary Care Assoc. November 5, 2010. Meaningful Use:

11/5/2010. Mara Robertson Tennessee Primary Care Assoc. November 5, 2010. Meaningful Use: Mara Robertson Tennessee Primary Care Assoc. November 5, 2010 1 Meaningful Use: What s the Big Deal! 2 1 ... 3 4 2 5 Internal Pressures 6 3 External Motivation President Promotes Switching To Electronic

More information

New Safe Harbors and Stark Exceptions for Electronic Prescribing and Electronic Health Records Arrangements

New Safe Harbors and Stark Exceptions for Electronic Prescribing and Electronic Health Records Arrangements New Safe Harbors and Stark Exceptions for Electronic Prescribing and Electronic Health Records Arrangements November 15, 2006 Steve Nash and Sara Hill, Holme Roberts & Owen LLP Agenda Introduction Background

More information

AUDITING TECHNIQUES TO ASSESS FRAUD RISKS IN ELECTRONIC HEALTH RECORDS

AUDITING TECHNIQUES TO ASSESS FRAUD RISKS IN ELECTRONIC HEALTH RECORDS AUDITING TECHNIQUES TO ASSESS FRAUD RISKS IN ELECTRONIC HEALTH RECORDS OBJECTIVE Increase your IT vocab so that you can assess the risks related to your audits of EHRs and/or EHR related data AGENDA What

More information

Unintended Consequences of Electronic Health Records

Unintended Consequences of Electronic Health Records Financial Disclosure Unintended Consequences of Electronic Health Records Mary Pat Johnson is a Senior Consultant at Corcoran Consulting Group and acknowledges a financial interest in the subject matter

More information

Electronic Health Record (EHR) Technology: Fraud & Abuse Risks and Compliance Strategies. Fraud and Abuse - Risks

Electronic Health Record (EHR) Technology: Fraud & Abuse Risks and Compliance Strategies. Fraud and Abuse - Risks 1 Electronic Health Record (EHR) Technology: Fraud & Abuse Risks and Compliance Strategies February 21, 2014 Attorney Advertising Prior results do not guarantee a similar outcome Models used are not clients

More information

MOUNT SINAI MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR

MOUNT SINAI MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR Department of Health and Human Services OFFICE OF INSPECTOR GENERAL MOUNT SINAI MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR Inquiries about this report may be addressed

More information

Industry leading Education Todays Webinar

Industry leading Education Todays Webinar Compliance Simplified Achieve, Illustrate, Maintain Industry leading Education Todays Webinar Please ask questions Todays slides are available http://compliancy- group.com/slides023/ Certified Partner

More information

Sunday March 30, 2014, 9am noon HCCA Conference, San Diego

Sunday March 30, 2014, 9am noon HCCA Conference, San Diego Meaningful Use as it Relates to HIPAA Compliance Sunday March 30, 2014, 9am noon HCCA Conference, San Diego CLAconnect.com Objectives and Agenda Understand the statutory and regulatory background and purpose

More information

HIPAA Secure Now! How MSPs Can Profit From Selling HIPAA security services

HIPAA Secure Now! How MSPs Can Profit From Selling HIPAA security services HIPAA Secure Now! How MSPs Can Profit From Selling HIPAA security services How MSPs can profit from selling HIPAA security services Managed Service Providers (MSP) can use the Health Insurance Portability

More information

What is the Meaning of Meaningful Use? How to Decode the Opportunities and Risks in Health Information Technology

What is the Meaning of Meaningful Use? How to Decode the Opportunities and Risks in Health Information Technology What is the Meaning of Meaningful Use? How to Decode the Opportunities and Risks in Health Information Technology Rick Rifenbark and Leeann Habte1 To achieve greater efficiencies in health care, enhanced

More information

William Rusty Huseman 3733 University Blvd. West, Suite 305-A Jacksonville, FL 32217

William Rusty Huseman 3733 University Blvd. West, Suite 305-A Jacksonville, FL 32217 William Rusty Huseman est, Email: Rusty@husemanhealthlaw.com 1 Audit & Compliance Audit Who can audit your practice? What to expect? What to do if you are audited? Compliance 2 What you MUST have in place

More information

Medicare Fraud. Programs supported by HCFAC have returned more money to the Medicare Trust Funds than the dollars spent to combat the fraud.

Medicare Fraud. Programs supported by HCFAC have returned more money to the Medicare Trust Funds than the dollars spent to combat the fraud. Medicare Fraud Medicare loses billions of dollars annually in fraud an estimated $60 billion in 2012 alone. In addition to outright criminal activity, the Dartmouth Atlas of Health Care (which studies

More information

Davis Wright Tremaine LLP Steve Lipton stevelipton@dwt.com. Robert G. Homchick roberthomchick@dwt.com

Davis Wright Tremaine LLP Steve Lipton stevelipton@dwt.com. Robert G. Homchick roberthomchick@dwt.com Davis Wright Tremaine LLP Steve Lipton stevelipton@dwt.com Robert G. Homchick roberthomchick@dwt.com In fall of 2007 CMS released the Phase III Final Stark Regulations Since then CMS has produced nothing

More information

EHR: The Good, Bad, and Ugly

EHR: The Good, Bad, and Ugly EHR: The Good, Bad, and Ugly Jonathan W. Lohr President Unibase Healthcare Solutions Kevin J. Corcoran, COE, CPC, CPMA, FNAO President, Corcoran Consulting Group Founder, Corcoran Compliance Connection

More information

Interpreting the HIPAA Audit Protocol for Health Lawyers

Interpreting the HIPAA Audit Protocol for Health Lawyers Interpreting the HIPAA Audit Protocol for Health Lawyers This webinar is brought to you by the Health Information and Technology Practice Group (HIT), and is co-sponsored by the Business Law and Governance

More information

EHR Incentive Payment: What Qualifies for the Medicare Cost Report. Kevin E. Wellen, CPA January 18, 2013

EHR Incentive Payment: What Qualifies for the Medicare Cost Report. Kevin E. Wellen, CPA January 18, 2013 EHR Incentive Payment: What Qualifies for the Medicare Cost Report Kevin E. Wellen, CPA January 18, 2013 EHR Incentive Payments Path to Payment Register Attest Payments Uses the Medicare and Medicaid EHR

More information

Quality Assurance Techniques for the Revenue Cycle. Top 5 Things to Know for CE: Disclaimer 3/31/10

Quality Assurance Techniques for the Revenue Cycle. Top 5 Things to Know for CE: Disclaimer 3/31/10 Quality Assurance Techniques for the Revenue Cycle Are You Prepared for an Audit? Judi Rooney, RN, MSHL, CHC Chartwell Home Therapies, LP Cindy Watson, Director PFSC Coram Specialty Infusion Services Top

More information

Shellie Sulzberger, LPN, CPC, ICDCT-CM Coding & Compliance Initiatives, Inc.

Shellie Sulzberger, LPN, CPC, ICDCT-CM Coding & Compliance Initiatives, Inc. Shellie Sulzberger, LPN, CPC, ICDCT-CM Coding & Compliance Initiatives, Inc. Reasonable efforts have been made to provide the most accurate and current information on CPT 2015 code changes. However codes,

More information

HIT Audit Workshop. Jeffrey W. Short. jshort@hallrender.com

HIT Audit Workshop. Jeffrey W. Short. jshort@hallrender.com HIT Audit Workshop Jeffrey W. Short jshort@hallrender.com 1 Audits and Investigations to be Discussed Meaningful Use Audits HIPAA Audits Data Breach Investigations Software Vendor Audits FTC Investigations

More information

Meaningful Use and Security Risk Analysis

Meaningful Use and Security Risk Analysis Meaningful Use and Security Risk Analysis Meeting the Measure Security in Transition Executive Summary Is your organization adopting Meaningful Use, either to gain incentive payouts or to avoid penalties?

More information

Security Concerns with Federal Emergency Management Agency's egrants Grant Management System

Security Concerns with Federal Emergency Management Agency's egrants Grant Management System Security Concerns with Federal Emergency Management Agency's egrants Grant Management System November 19, 2015 OIG-16-11 DHS OIG HIGHLIGHTS Security Concerns with Federal Emergency Management Agency s

More information

Medicaid Fraud and Abuse Investigations, Prosecutions and Compliance Strategies

Medicaid Fraud and Abuse Investigations, Prosecutions and Compliance Strategies Combating Medicaid Fraud & Abuse: Implications of the Medicaid Integrity Program October 24, 2006 Medicaid Fraud and Abuse Investigations, Prosecutions and Compliance Strategies John T. Bentivoglio jbentivoglio@kslaw.com

More information

DEPARTMENT OF HEALTH AND HUMAN SERVICES OFFICE OF INSPECTOR GENERAL

DEPARTMENT OF HEALTH AND HUMAN SERVICES OFFICE OF INSPECTOR GENERAL i~o:~~~~"i: "" J[( DEPARTMENT OF HEALTH AND HUMAN SERVICES OFFICE OF INSPECTOR GENERAL 'llfl,.m~ WASHINGTON, DC 20201 TO: APR 1 3 2012 Marilyn Tavenner Acting Administrator Centers for Medicare & Medicaid

More information

Department of Health and Human Services OFFICE OF INSPECTOR GENERAL

Department of Health and Human Services OFFICE OF INSPECTOR GENERAL Department of Health and Human Services OFFICE OF INSPECTOR GENERAL HIGH-RISK SECURITY VULNERABILITIES IDENTIFIED DURING REVIEWS OF INFORMATION SYSTEM GENERAL CONTROLS AT THREE CALIFORNIA MANAGED-CARE

More information

Physician EHR Subsidies under Stark. and the Anti-Kickback Statute

Physician EHR Subsidies under Stark. and the Anti-Kickback Statute Key Legal Issues Raised by Electronic Health Physician EHR Subsidies under Stark Records Technology and the Anti-Kickback Statute Friday, November 18, 2011 Attorney Advertising Prior results do not guarantee

More information

June 26, 2009. RE: HIT Policy Committee Meaningful Use Comments. Dear Dr. Blumenthal:

June 26, 2009. RE: HIT Policy Committee Meaningful Use Comments. Dear Dr. Blumenthal: June 26, 2009 David Blumenthal, MD, MPP National Coordinator Office of the National Coordinator for Health Information Technology 200 Independence Avenue, SW Suite 729D Washington, DC 20201 RE: HIT Policy

More information

HIPAA Omnibus Rule Overview. Presented by: Crystal Stanton MicroMD Marketing Communication Specialist

HIPAA Omnibus Rule Overview. Presented by: Crystal Stanton MicroMD Marketing Communication Specialist HIPAA Omnibus Rule Overview Presented by: Crystal Stanton MicroMD Marketing Communication Specialist 1 HIPAA Omnibus Rule - Agenda History of the Omnibus Rule What is the HIPAA Omnibus Rule and its various

More information

6/8/2012. Cloning and Other Compliance Risks in Electronic Medical Records

6/8/2012. Cloning and Other Compliance Risks in Electronic Medical Records Cloning and Other Compliance Risks in Electronic Medical Records Lori Laubach, Partner, Moss Adams LLP Catherine Wakefield, Vice President, Corporate Compliance and Internal Audit, MultiCare 1 AGENDA Basic

More information

Identity: The Key to the Future of Healthcare

Identity: The Key to the Future of Healthcare Identity: The Key to the Future of Healthcare Chief Medical Officer Anakam Identity Services July 14, 2011 Why is Health Information Technology Critical? Avoids medical errors. Up to 98,000 avoidable hospital

More information

Meaningful Use Crosswalk to the Security Rule

Meaningful Use Crosswalk to the Security Rule Meaningful Use Crosswalk to the Security Rule Safeguarding Health Information: Building Assurance through HIPAA Security June 7, 2012 Adam H. Greene, J.D., M.P.H. Partner, Davis Wright Tremaine EHR Certification

More information

Accountable Care Organization. Medicare Shared Savings Program. Compliance Plan

Accountable Care Organization. Medicare Shared Savings Program. Compliance Plan Accountable Care Organization Participating In The Medicare Shared Savings Program Compliance Plan 2014 Corporate Location: 3190 Fairview Park Drive Falls Church, VA 22042 ARTICLE I INTRODUCTION This Compliance

More information

AHLA. Y. Advising Providers in Adopting or Substituting a Health IT System. Charles C. Dunham Bond Schoeneck & King PLLC Albany, NY

AHLA. Y. Advising Providers in Adopting or Substituting a Health IT System. Charles C. Dunham Bond Schoeneck & King PLLC Albany, NY AHLA Y. Advising Providers in Adopting or Substituting a Health IT System Charles C. Dunham Bond Schoeneck & King PLLC Albany, NY Health Care Transactions April 10-11, 2014 Advising Providers in Adopting

More information

HEALTH CARE FRAUD AND ABUSE CONTROL PROGRAM

HEALTH CARE FRAUD AND ABUSE CONTROL PROGRAM United States Government Accountability Office Report to Congressional Requesters September 2013 HEALTH CARE FRAUD AND ABUSE CONTROL PROGRAM Indicators Provide Information on Program Accomplishments, but

More information

THE INFORMATION TECHNOLOGY INFRASTRUCTURE

THE INFORMATION TECHNOLOGY INFRASTRUCTURE Department of Health and Human Services OFFICE OF INSPECTOR GENERAL THE INFORMATION TECHNOLOGY INFRASTRUCTURE AND OPERATIONS OFFICE HAD INADEQUATE INFORMATION SECURITY CONTROLS Inquires about this report

More information

Society of Corporate Compliance and Ethics

Society of Corporate Compliance and Ethics Society of Corporate Compliance and Ethics 8 th Annual Conference for Effective Compliance Systems in Higher Education We Are Special!! The Special Need for Contract Management for the Health Sciences

More information

(EHR) Incentive Program

(EHR) Incentive Program ATTESTATION USER GUIDE For Eligible Professionals Medicare Electronic Health Record (EHR) Incentive Program 2014 Stage 1 Definition of Meaningful Use June 2014 CONTENTS Click on the Step below to navigate

More information

MEDICAID DRUG PRICE COMPARISON: AVERAGE SALES PRICE TO AVERAGE WHOLESALE PRICE

MEDICAID DRUG PRICE COMPARISON: AVERAGE SALES PRICE TO AVERAGE WHOLESALE PRICE Department of Health and Human Services OFFICE OF INSPECTOR GENERAL MEDICAID DRUG PRICE COMPARISON: AVERAGE SALES PRICE TO AVERAGE WHOLESALE PRICE Daniel R. Levinson Inspector General June 2005 OEI-03-05-00200

More information

HIPAA and Beyond: The Evolving Landscape of Health Privacy

HIPAA and Beyond: The Evolving Landscape of Health Privacy HIPAA and Beyond: The Evolving Landscape of Health Privacy Melissa Bianchi, Hogan Lovells US LLP Ann Tobin, UnitedHealth Group IAPP Global Privacy Summit, March 9, 2012 No Longer Just HIPAA New developments

More information

Review of Medicaid Upper-Payment-Limit Requirements for Kansas Nursing Facility Reimbursement (A-07-03-02672)

Review of Medicaid Upper-Payment-Limit Requirements for Kansas Nursing Facility Reimbursement (A-07-03-02672) DEPARTMENT OF HEALTH & HUMAN SERVICES Office of Inspector General '%..,- Washington, D.C. 20201 TO: Mark B. McClellan, M.D., Ph.D. Administrator Centers for Medicare & Medicaid Services FROM: Daniel R.

More information

EMR SHARING AND CONTRACTING ISSUES, RISKS AND PITFALLS KEVIN M. MOONEY, ESQ. COUNSEL/CHAIR IT PRACTICE GROUP THE CLEVELAND CLINIC FOUNDATION

EMR SHARING AND CONTRACTING ISSUES, RISKS AND PITFALLS KEVIN M. MOONEY, ESQ. COUNSEL/CHAIR IT PRACTICE GROUP THE CLEVELAND CLINIC FOUNDATION EMR SHARING AND CONTRACTING ISSUES, RISKS AND PITFALLS KEVIN M. MOONEY, ESQ. COUNSEL/CHAIR IT PRACTICE GROUP THE CLEVELAND CLINIC FOUNDATION 1 WHAT ARE WE TALKING ABOUT? HEALTH INFORMATION IT SECURITY

More information

HCCA Audio Conference 2015 OIG Work Plan Part B Physicians and Non-physician Providers November 20, 2014

HCCA Audio Conference 2015 OIG Work Plan Part B Physicians and Non-physician Providers November 20, 2014 HCCA Audio Conference 2015 OIG Work Plan Part B Physicians and Non-physician Providers November 20, 2014 1 OIG Overview Mission To protect the integrity of HHS programs and the health and welfare of the

More information

Health Care Compliance Association 888-580-8373 www.hcca-info.org

Health Care Compliance Association 888-580-8373 www.hcca-info.org Volume Thirteen Number Six Published Monthly Meet Danna Teicheira, System Privacy Officer at St. Luke s Health System page 16 Earn CEU Credit www.hcca-info.org/quiz see page 19 Compliant DMEPOS telemarketing:

More information