HHS has extended the Public Health Emergency for another 90 days (until October 13, 2022). Moreover, if HHS decides to terminate the PHE...

1. Projected AMA Bundling. The 2023 Medicare Proposed Rule for the Physicians Fee Schedule states that the AMA is going to revise the...

We have attended several educational telephone calls with Noridian Medicare regarding its nationwide facet audits. If you are audited by...

This week one of my clients sent me an audit by UHC which denied the client’s central line placement. UHC’s auditors took the position...

1. Scope of This Article. The purpose of this article is to differentiate between the required federal level of CRNA supervision in the...

The Office of Civil Rights ("OCR") has published 4 recent enforcement actions for alleged HIPAA breaches, as follows: 1. Copies of...

Overview. Would you like to have the OIG's playbook on how it will audit your facet blocks and RF procedures? We have it. The OIG is...

New Coverage Memorandum. On March 25, 2022, CMS issued a Memorandum (“TDL-220299”), revoking prior instructions, and providing new...

On February 23, 2022, a federal district court in Texas held that the IDR (Independent Dispute Resolution) process in the NSA (No...

On January 27, 2022, a federal district court in Utah ruled that a vascular surgeon’s False Claims Act case against an anesthesia group...

If you are wondering what verbiage to use for your Disclosure Notice and your Notice and Consent forms required under the Surprise...

The 2022 Medicare Physician’s Fee Schedule Final Rule was released last week, containing over 2,000 pages. Introduction. Here are some...

1. New OIG Opinion. Today the OIG emailed me a formal Advisory Opinion (21-15) which I requested 2 ½ years ago regarding whether it is...

New Epidural LCDs Effective in December. Effective this December all Medicare carriers have adopted a new epidural LCD that rewrites the...

Make sure you are waiting to review the results of your presumptive UDTs before ordering the confirmations. Two months ago, a pain...

The OIG just released nationwide audit results of stimulator implants, wherein it found that 40% of the claims did not contain sufficient...

1. New Medicare Auditing Metrics. When it comes to the likelihood of your group being audited by Medicare for excessive urine drug...

1. New Interim Rule. On September 30, 2021, CMS released its 2nd Interim Final Rule (the “Rule”; which is 520 pages long) detailing how...

Many of you received Provider Relief Funds (“PRF”) which initially just showed up in your bank account without requesting it. ...

1. FCA Settlement. On June 25, 2021, the U.S. Department of Justice (“DOJ”) issued a press release regarding a $1,002,481 settlement it...

Effective July 1, 2021, CMS has added cervical fusion with disc removal (22551/22552) and implanted spinal neurostimulator electrodes...

On July 1, 2021, HHS released the Interim Final Rule regarding the No Surprises Act (the “Act”) which was signed into law on December 27,...

1. Billing Fluoro with Pump Refill. In the June 2021 issue of the AMA’s CPT Assistant, the AMA stated that it would be appropriate to...

For many years our clients have debated on whether to bill a popliteal fossa block as a sciatic nerve block (64445) or as a peripheral...