Category: Affordable Care Act

More Surprises from the Affordable Care Act

ACA section 10606(a) affirms the applicability of the Federal Sentencing Guidelines, which I previously discussed.  Additionally, in 10606(b) states, “With respect to violations of this section (Healthcare Fraud), a person need not have actual knowledge of this section or specific intent to commit a violation of this section.’’ Let this simmer for a second… To [..]

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Medicaid Provider, are you (or your employees) excluded and don’t even know it?

In a previous article where I discussed the purpose of a compliance program I mentioned that recent enforcement/ prosecution trends indicate that the government is not necessarily seeking prison time for convictions. The trend is to exclude providers from participation in the Federal health care programs and require repayment of Civil Monetary Penalties under the [..]

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How can a Compliance Program Save your Bacon?

In 2011 the Federal Sentencing Guidelines were revised to strengthen that due consideration be given to organizations found guilty of wrongdoing when an organization has a “reasonably effective compliance program”. This does not require that a compliance program be perfect, just that there is a great likelihood that a situation that is not caught likely [..]

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Compliance Programs

If you accept money from a federally funded health plan you are required by section 6401(7) to “establish a compliance program that contains the core elements” prescribed by the (Federal) Office of the Inspector General, which states providers, “shall have in operation a compliance and ethics program that has been reasonable designed, implemented and enforces [..]

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A Closer Look at the Core Elements of a Dental Compliance Program

In a previous article I identified for you the Office of the Inspector General’s recommended core elements for establishing a compliance program. Let’s quickly review them and then we will take a closer look at what they mean for your dental practice.   Conducting internal monitoring and auditing through the performance of periodic audits Implementing [..]

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Federally Funded Dental Care Programs

Okay, here it is – sections 6401 and 6402 of the Affordable Care Act requires formalized compliance programs by providers and stringent screening of providers (those of submit claims) to Federally funded health plans, including, but not limited to: Medicare, Medicaid, CHIP, TRICARE, Indian Health Services, State and Federal Employee and State and Federal Retiree [..]

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