You would like the group to purchase an X-Ray machine as an …
You would like the group to purchase an X-Ray machine as an ancillary diagnostic service to their medical practice. The group agrees but insists that all fees for the technical component billed to Medicare for the X-Rays should be split up based solely upon who ordered the test. (The technical component is the charge for the X-Ray itself and is not for the professional part of the radiologist or other doctor who reads or interprets the X-Ray.) Also, there is not enough space at the office building where the group practices to house the MRI machine so they want to lease space in the building next door for the MRI. What is your response to these proposals.
(I suggest looking to the fraud and abuse regulations to find support for your answers i.e. Stark and the Anti-Kickback Act. First, determine whether the laws apply and then see if there is a Stark exception or Anti-Kickback safe harbor that addresses this ancillary service and if the proposals are compliant with those exceptions or safe harbors. If not, why not?)
You are the compliance officer of a Medicare certified hospice. In reviewing this month’s claims submitted for payment to Medicare you discover that of the 15 new hospice admissions, for the first 90 days of hospice coverage, the medical records contain 10 written certifications of terminal illness signed by the hospice medical director within 48 hours of the initiation of service; 2 were written and signed but only after 5 days from the initiation of service and 3 have no written certifications at all, however, your staff confirms that for those last three, each of the patient’s attending physician verbally certified the terminal illness. All of the written certifications state the time frame for life expectancy for the newly admitted patients, however, the staff forgot to verify the time frame of life expectancy in their verbal conversations with the 2 attending physicians who gave verbal certificates. You decide to call the two attending physicians. What time frame of life expectancy do you need to confirm? Also, of these 15 new claims, how many do you think could be denied for payment by Medicare and why?
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