Audits continue to ramp up, for a variety of practices. COVID-19 audits are occurring, as are normal compliance and HIPAA audits.
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Recently, the Department of Justice (DOJ) settled allegations against Sutter Health for $90 million dollars and participation in a Corporate Integrity Agreement.
Allegations against Sutter Health include knowingly submitting or causing to be submitted risk adjusted diagnosis codes that were false or not supported. This resulted in alleged inflated payments to Sutter Health through Medicare Advantage Organizations.
Under the Medicare Advantage program, CMS pays Medicare Advantage Organizations payments which are risk adjusted for certain demographic factors and the health status of the beneficiary.
More risk adjusted diagnosis codes results in higher payments to the Medicare Advantage Organization.
In the Sutter Health settlement, the allegations were brought to light by a whistleblower.
More often than not, a whistleblower first looks to report wrongdoings internally. If an organization has sufficient anonymous reporting and takes reports seriously, many whistleblower issues can be avoided.
If you think your practice needs a refresher to avoid a costly audit, contact your healthcare attorney today. We help our practices make sure their compliance plans are up to date, their billing is correct, and that they have adequate reporting mechanisms. We also help train staff to ensure that everyone knows how to report potential issues, so they know their internally reported concerns will be taken seriously.
Audits are ongoing and you need to protect your practice by ensuring that you have proper policies in place.
Remember, any staff member can become a whistleblower if they feel as though their concerns are not being addressed.
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