2024 MIPS Final Scores Won’t Publish Until Fall
Download the 2024 MIPS scoring guide for more information on performance criteria and how final scores are calculated.
CMS Warns of Fraud Scheme Around Medicare Audits
CMS has identified a fraud scheme targeting Medicare providers and suppliers. If you receive a suspicious request, don’t respond.
DEA Warning: Fraudsters Impersonating DEA Officials are Scamming Clinicians
Federal law enforcement officers are prohibited from demanding cash or gift cards from a member of the public.
Hyperbaric Physicians (and Hospital Program Managers): Check the 2023 Medicare Data! Protect Your NPI and Don’t Put Hospital Facility Fees at Risk
Check the 2023 Medicare data! Protect your NPI and don’t put hospital facility fees at risk.
Just Released: Hospital Outpatient Proposed Rule Would “Unbundle” Cellular Tissue Products (CTP) / Skin Substitutes in the HOPD
I will try to post a better analysis of the impact of these proposals in the HOPD (hopefully provided by readers who understand this better than I do).
Show Me the Regulation!
When clinicians or management companies ask why a process must be done in a certain way, they are told, “It’s a regulatory requirement.”
BREAKING: 2026 MPFS Proposed Rule sets single payment for all CTPs at $125.38/cm2
There will no doubt be a significant response from manufacturers and clinicians in response to this proposal.
Scam Alert! CMS Issues Warning on Medicare Audit Phishing Scheme
Increased awareness of the Medicare audit climate could cause clinicians to be fooled by these scams. Watch out!
RFK Jr. and Dr. Oz Pledge to Fix Broken Prior Authorization System
heir commitments reinforce the role of CMS in monitoring outcomes and promoting accountability.
BREAKING NEWS in the DOJ Press Conference! More Skin Substitute / Cellular Tissue Product (CTP) Fraud Indictments
Wound Care, specifically around the use of amniotic “skin substitutes,” made the news in the fraud press release.
Site Neutrality – a Looming Disaster or an Opportunity?
Now may be the time for academic programs and large hospital systems that still provide needed emergency hyperbaric services to start contacting their congressmen.
The Quality Payment Program (QPP) “Doctors and Clinicians Preview Period” for 2023 is Officially Open
Clinicians who reported data as part of the Quality Payment Program (QPP) in 2023 can preview their 2023 performance information before it appears on the Medicare.gov compare tool and in the Provider Data Catalog (PDC).
DOJ Unveils a New Corporate Enforcement & Voluntary Self-Disclosure Policy (CEP)
The Department of Justice’s Criminal Division is “turning a new page on white-collar and corporate enforcement.”
Providers Under Siege
The stakes go beyond money: reputational harm, exclusion from Medicare and Medicaid, and even criminal charges are on the table.
States Try to Limit the Use of AI in Prior Authorization
Read the complete article for more details on what individual states are doing to push back on the use of AI in Prior Authorization.
CTP-related LCDs Postponed at the Last Minute!
The LCDs that will directly impact CTPs (Skin Subs) have been postponed until January 1, 2026! Announcement came at the last minute!
Overzealous Medicare Audits
Be sure to read all of Ms. Emanuel’s article, which calls for radical reforms such as holding auditors accountable for mistakes.
Hospitals & Doctors Spend a Lot of Money Just Trying to Get Paid
No wonder practitioners in private practice have been tempted by the big dollars to be made from skin substitutes.
What Happened to “Innocent Until Proven Guilty? Check Out this Article on Medicare Recoupment
Check out Knicole Emanuel’s recent blog post about CMS monetary recoupment before full adjudication.
Fewer Regulatory Hoops but Continued Scrutiny on Fraud Under the Trump Administration
While the Trump Administration may be reducing the regulatory burden in many areas of government, they are NOT reducing their focus on reducing on fraud investigations.
The Cigna Group Launches Actions to “Drive Positive Change for Customers & Patients”
There are five key areas of focus, and several initial specific actions, to improve the health of its customers and the value it provides.
ACA Healthcare Plan “Just Say No” to 1 in 5 Claims
ACA insurers denied 1 in 5 medical claims in 2023, the highest rate since 2015.
Murphy Introduces Bipartisan Legislation to Preserve Medicare for Patients and Physicians
I worry that the misbehavior of a small percentage of practitioners will reduce enthusiasm for a bill to fix a huge physician reimbursement problem.
A Titanic Shift at CMS: The Push to Trim Administrative Costs & Increase Audits – Knicole Emanuel’s Recent Post
Ms. Emanuel likens CMS to the Titanic in terms of how hard it will be to turn such a massive ship. Let’s hope this story will end differently.
“Defending Against Medicare and Medicaid Audits: A Guide for Healthcare Providers” by Knicole Emanuel
She notes that, “Recent statistics show that CMS, through its contractors, conducted over 300,000 audits in recent years.”
Noridian Surgical Dressings Webinar – 02/11/2025
The Noridian Provider Outreach and Education staff is hosting the Surgical Dressings webinar on 02/11/2025, 12:00 PM – 1:30 PM EST.
Landmark Antitrust Settlement Calls for Blue Cross Blue Shield to Pay $2.8 Billion into a Fund Designated for Physicians and Others
The fund is designated for settlement class members, including physicians, group practices, and health care facilities.
LCDs Delayed Until April 13, 2025
If you scroll to the end of the LCD, it will state the future effective date of 4/13/25.
American Relief Act Extends Some Telehealth Waivers Including Audio-Only Telehealth
The continuation of Medicare telehealth flexibilities follows another recent telemedicine extension by the DEA and the Department of HHS.
BREAKING NEWS: Wound Care Company Owners Plead Guilty to $1.2 B in Fraudulent Claims for Amniotic Products and Face Prison
The case was handled through the Health Care Fraud Strike Force Program, which currently operates in nine Strike Forces across the country.
Physicians Have Concerns Over the Implementation of Medicare’s Add-on Code for Complex Care (G2211)
The rules are complex, and a billing and coding expert may need to provide guidance to wound care practitioners.
Changes to the Administrative False Claims Act (AFCA) Mean That “Smaller” Medicare Fraud Cases (Up to $1 Million) Can Be More Easily Prosecuted
This legislation also makes it more likely that individuals who act as “whistleblowers” could realize the associated monetary rewards.
The New LCDs are (Almost Certainly) Coming to Town
I may post more information about the meeting later, but the general tone of the MAC medical directors was confident.
CGS Chief Medical Officer is Hosting a Meeting on the New Cellular Tissue Product / Skin Substitute LCD on December 20th
CGS J15 Webinar on Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers
AMA sues MultiPlan Alleging Price-Fixing for Out-of-Network Physician Payments
The American Medical Association (AMA) and the Illinois State Medical Society (ISMS) have filed a lawsuit in federal court.
CMS Releases the Medicare Physician Fee Schedule Final Rule for 2025
The sad news is that CMS is going ahead with a 2.9% cut to Medicare physician reimbursements for 2025.
ICD-10 Changes
There were 252 new codes added, 36 code deletions, and 13 code revisions effective October 1, 2024.
CMS Releases 2025 Final Rule for the Hospital Outpatient Prospective Payment System (OPPS)
The short version, based on my cursory read, is that no old problems were fixed but no new problems were created by the final rule.
Breaking News! LCDs for Cellular Tissue Products / Skin Substitutes Released!
LCD – Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers (L39756)
Bipartisan Bill Introduced That Would Provide a 4.7% Medicare Physician Payment Update
It would eliminate the 2.8% Medicare physician payment cut and provide a positive update that equals half of the Medicare Economic Index.
FDA Approves Changing the Expiration Date of Some IV Fluids Made by Baxter to Help Alleviate Shortages
Baxter International is one of the largest suppliers of IV fluids in the United States with its North Cove facility providing 60% of IV fluid in the USA.
Check Your Final 2023 MIPS Scores Available Online – Scores Will Impact 2025 Physician Payment!
Should an error be found, the deadline to request a review is Oct. 11 at 7 pm CT.
“To Self-Disclose or Not to Self-Disclose”: Check Out Attorney Knicole Emanuel’s Blog
Self-disclosure is better than waiting to get caught. Lives can be ruined if you wait to get caught.
Templated Notes and Medicare Audits
If practitioners encounter denials by auditors based on the use of note templates, they should probably seek legal counsel.
Loss of Baxter Facility in N.C. from Helene is Affecting Availability of IV Solution and Shortages May Worsen Due to Hurricane Milton
Hospitals are facing shortages of IV fluids following Hurricane Helene’s damage to Baxter International’s North Cove manufacturing site in Marion, N.C.
Reminder: Final Scores for the 2023 Performance Year of Medicare’s Merit-Based Incentive Payment System (MIPS) are Now Available Online and the Deadline to Request a Review is October 11 at 8 PM ET
Check your scores soon as they will impact your 2025 Medicare payment!
UnitedHealthcare Launches a “Gold Card” Program in October to (Hopefully) Reduce Prior Authorization Woes
The program will be offered across its commercial, individual exchange, Medicare Advantage and Medicaid business lines.
Due to the Impact of Beryl, CMS Has Automatically Applied a Hardship Exemption Within the 2024 Merit-Based Incentive Payment System (MIPS) Performance Period to Eligible cC Areas
The extreme and uncontrollable circumstances (EUC) policy will apply in affected Texas counties as identified by federal public health emergency and disaster declarations.
Check Out the New Article in TWC “I’m Getting Audited – Now What?” by Stephen Bittinger
Mr. Bittinger’s article explains the various types of audits, what’s at stake, and how an attorney might help.
Aetna to Cut Payment for Urgent Care Surgical Services and Payments for NPs and PAs
Wound Care practitioners who bill site of service 49 (independent clinic) take note!