Healthcare Fraud Investigations: How Healthcare Compliance Programs Save Your Practice & Freedom
Featuring Tom Rhudy
- Accept what the insurance carrier offers, without question n
- Work with 3rd- party liability carriers and accept what your patients give you once they receive settlement, and accept your patient's account of settlement negotiations n
- Allow your patients to retain an attorney to handle 3rd-party liability claims, and you accept the attorney's offer of settlement without questionn
- Work consistently with a limited number of external providers (physicians, surgeons, neurologists)
- Fail to read the Explanations of Benefits ("EOBs") in which the insurance carrier identifies the reasons for denial.
- Consider peer reviewers' reports as nuisances and as costs of doing business with insurance carriers.
- Not bother to read, or don't receive, Controverting Affidavits in which both reasons for denial are reported and aberrant practices are alleged.
- Fail to respond to Controverting Affidavits in which reasons for denial are reported.
- Fail to respond to Controverting Affidavits in which aberrant practices (unbundling of services, medically unnecessary services, medically unnecessary referrals) are alleged, because you either consider such allegations harmless or you have neither the time nor ability to provide a response challenging such allegations.
- Develop a healthcare compliance program. Do not make the mistake of believing that a sham compliance program will suffice. You are better off having no compliance program than merely using one for window-dressing. The false sense-of-security often proves disastrous!
- Create an audit-response program that effectively addresses deficiencies, both noted and alleged.
- Establish a policy for refunds of monies paid in error, when such errors are noted during internal audits.
- Develop an effective auditing process, assessing medical necessity and billing issues.
- Meet with SIU agents who may have "flagged" your files to identify specific areas of concern.
- Develop a Hotline to address issues of concern coming from employees, patients, insurance adjusters, etc.
- Attempt to enter into a Corporate Integrity Agreement between the targeted-provider and investigators.
- Retain a compliance team knowledgeable in healthcare law. Do not trust your fate to an attorney inexperienced in this arena. Rest assured, the insurance carriers will not!
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