On November 10, 2019, CMS issued a final Federal Register with comment period. Both the implementation and comment period had a date of November 4, 2019. In this sentry CMS creates a whole new set of definitions and rules to the Code of Federal Regulations, namely 42 CFR §424. This is the Conditions for Payment (CfP) section of the CFR. The main issue addressed is to have providers report any affiliations both current and those that go out five years. The intent of the new definitions and rules is to identify any bad actors that might be affiliated with legitimate providers.
Reporting is to occur through the various CMS-855 forms. At least to begin the process, new enrollees and revalidations will be affected. Of greatest concern are the definitions of terms like affiliation and disclosable event. Who is to report, how the reporting is to occur, possible penalties, and the appeals process are also discussed.
This is a major compliance issues for hospitals, clinics, physicians and all types of providers using the CMS-855 forms.
- What are these CMS-855 forms?
- How are the CMS-855 forms affected by affiliation reporting?
- When you we have to start reporting affiliations?
- What affiliations must be reported?
- Just what is an affiliation?
- What is a disclosable event?
- What information must be disclosed?
- What happens if the proper information is not reported?
- What is this concept of undue risk?
- What is the reapplication process?
- Are programs other than Medicare affected?
- To review the Medicare enrollment process through the use of the various CMS-855 forms.
- To address changes to the CMS-855 forms and the reporting process.
- To understand what is considered an affiliation.
- To appreciate the information that must be supplied.
- To understand when to report affiliations.
- To appreciate what happens if affiliations are not correctly reported.
- To understand the concept of disclosable events.
- To appreciate the concept of undue risk.
- To understand when and how to reapply.
- To appreciate why CMS is requiring the reporting of affiliations.
- Conditions for Payment – 42 CFR 424
- Review of the CMS-855 Forms
- Why CMS is Requiring the Reporting of Affiliations
- Disclosable Events
- Undue Risk
- Information The Must Provided
- Affiliated Organization Name
- Legal Business Name/Doing Business As Name
- Affiliation Relationship
- When Must Affiliation Reporting Occur?
- New Enrollment
- Impacts of Not Reporting Affiliations
- Denial and Revocation
- Payment Suspension
- Other Programs
- Case Studies
- Future Requirements for Conditions for Payment
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About the Presenter:
Duane C. Abbey, PhD, CFP, is a management consultant and president of Abbey & Abbey Consultants, Inc., a consulting firm specializing in healthcare and related areas. Duane earned his graduate degrees at the University of Notre Dame and Iowa State University and has more than 20 years of experience as a consultant. Dr. Abbey works extensively in all areas relating to compliance reviews, coding, billing and reimbursement with particular emphasis on the chargemaster and outpatient payment. His consulting activities include hospitals and physicians based clinics.
In addition to his consulting practice, Dr. Abbey also teaches workshops and makes presentations on a regular basis. He has taught at the University level and speaks nationally. He is a regular presenter for hospital associations, medical societies, Boards of Trustees and various other organizations and groups. In addition, professional societies such as HFMA use Dr. Abbey’s services to present seminars and workshops.
Dr. Abbey is a nationally recognized expert in payment systems. A special area of expertise includes APGs/APCs. He is recognized as the leading expert in the nation in APGs/APCs by the thousands who have attended his seminars, read his publications and/or contracted for his services. Attendees at these seminars over the years have included personnel from hospitals, clinics, integrated delivery systems and multiple consulting firms.
Dr. Abbey is also the author of numerous articles and books including: Compliance for Coding, Billing & Reimbursement, Outpatient Services: Designing, Organizing & Managing Outpatient Resources, ChargeMaster: Review Strategies for Improved Billing and Reimbursement, Ambulatory Patient Group Operations Manual, published by McGraw-Hill and Non-Physician Providers: Guide to Coding, Billing & Reimbursement, Chargemasters: Strategies to Ensure Accurate Reimbursement and Compliance, and Emergency Department Coding & Billing: A Guide to Reimbursement & Compliance published.
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