PYA Alerts

As issues arise we try to inform our friends and clients in a timely manner via PYA Alert.   If you would like to receive important updates on healthcare issues via the PYA Alert, please click here.

Recovery Audit Contractor (RAC) Overpayments - Protecting Today's Medicare Claims for Tomorrow's Audit
(PYA Alert dated May 6, 2008)
Following the March 2008 conclusion of the 3-year RAC demonstration project, or “demo”, the Centers for Medicare & Medicaid Services (CMS) is expanding the RACs to the national level by 2010...Click here for entire Alert

Is it time for your hospital to renew an agreement with a physician who provides administrative services?
(PYA Alert dated April 24, 2008)
Do most of your physician-hospital arrangements which involve administrative activities, such as medical directorships, include “automatic” renewals over a multi-year contract?..Click here for entire Alert

Real Estate Update
(PYA Alert dated February 18, 2008)
Many physician groups are considering ownership opportunities for their medical real estate..Click here for entire Alert

Deficit Reduction Act (DRA) Compliance - Do you have everything in place?
(PYA Alert dated January 16, 2008)
Do you realize that we’ve just seen the first anniversary of the requirement for healthcare providers to be in compliance with DRA provisions (as of January 1, 2007)? Oh how time flies..Click here for entire Alert

Is Your Facility Prepared for the Mountain State BCBS Conversion to the Outpatient Prospective Payment System (OPPS)?
(PYA Alert dated January 10, 2008)
Effective for services rendered on or after January 1, 2008, MSBCBS will begin processing hospital outpatient claims under CMS’s Outpatient Prospective Payment System (“OPPS”). This will affect the following MSBCBS products:...Click here for entire Alert

CMS Applies a Validation Process for Reporting 2007 PQRI Measures
(PYA Alert dated January 2, 2008)
As required by the Tax Relief and Health Care Act of 2006 (TRHCA), the 2007 Physician Quality Reporting Initiative (PQRI) will include a validation process. This CMS validation process will focus...Click here for entire Alert

Agencies Issue Final Rules on Identity Theft
(PYA Alert dated November 30, 2007)
The federal financial institution regulatory agencies and the Federal Trade Commission are jointly issuing final rules on identity theft “red flags” and mailing address discrepancies...Click here for entire Alert

Recovery Audit Contractors: What is it and when will it affect you?
(PYA Alert dated November 30, 2007)
Recovery Audit Contractors ("RAC") has been piloted in California, Florida and New York. The role of the RAC is to identify improper payments, both overpayment or underpayment that resulted from...Click here for entire Alert

CMS Releases SSI Files for 2005 - 2006
(PYA Alert dated November 14, 2007)
On November 1, 2007, the Centers for Medicare and Medicaid Services (CMS) released the 2005-2006 Supplemental Security Income (SSI) hospital calculations. The SSI percentage is based on...Click here for entire Alert

Regulators Release Revised Bank Secrecy Act/Anti-Money Laundering Examination Manual
(PYA Alert dated November 9, 2007)
The Federal Financial Institutions Examination Council (FFIEC) recently released the 2007 version of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual...Click here for entire Alert

CMS Releases Wage Index Files for Review
(PYA Alert dated October 24, 2007)
The Centers for Medicare and Medicaid Services (CMS) released the FY 2009 wage index files on October 5, 2007. These files contain...Click here for entire Alert

Hospital/Physician Relationships will need to pass the transparency test for new Disclosure of Financial Relationships Report ("DFRR")
(PYA Alert dated October 22, 2007)
Attention Hospital Administrators: The Centers for Medicare and Medicaid Services (“CMS”) has initiated a pilot program entitled The Disclosure of Financial Relationships Report (“DFRR”). Efforts to monitor...Click here for entire Alert

Inpatient Claims May Have a Short Delay
(PYA Alert dated October 16, 2007)
The Centers for Medicare & Medicaid Services (CMS) issued a Joint Signature Memorandum (JSM-07548) dated September 28, 2007. In this memo...Click here for entire Alert

CMS Releases Stark, Phase III Final Rule -
Impact to Safe Harbor Calculations?
(PYA Alert dated August 30, 2007)
Implications to Determination of Fair Market Value Compensation for Physician Services
CMS recently released a display copy of the Stark physician self-referral prohibition, Phase III regulations. Phase III final rule is a response to public comments on the Phase II interim final rule published March 26, 2004...Click here for entire Alert

CMS Revises ASC Payment System
(PYA Alert dated August 21, 2007)
On July 16, 2007, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule establishing the policies for the revised payment system for Ambulatory Surgical Centers (“ASCs”) beginning in 2008...Click here for entire Alert

Summarized 2008 OPPS Proposed Rule - What is Significant?
(PYA Alert dated August 14, 2007)
The 2008 proposed OPPS rule stands to impact every organization through implementation of key changes, designed to promote more efficient care in hospital outpatient departments for greater flexibility in managing these resources...Click here for entire Alert

Inpatient Prospective Payment System (IPPS) Final Rule Implements New MS-DRG's
(PYA Alert dated August 10, 2007)
On August 1, 2007, CMS displayed an advance copy of the final rule for Medicare's IPPS effective for discharges on or after October 1, 2007. Approximately 900 public comments were submitted on the proposed rule published in April demonstrating this rule contains some of the most significant IPPS changes since 1983....Click here for entire Alert

Tennessee Bill Changes...
(PYA Alert dated July 17, 2007)
Tennessee Bill Changes Limits on Uninsured Charges On June 11, 2007, Governor Phil Bredesen signed Senate Bill 2292 which places limits on what healthcare facilities in Tennessee may charge uninsured patients.....Click here for entire Alert

"Under Arrangements" soon to be "Over the Hill"?
(PYA Alert dated July 12, 2007)
CMS Proposed Revisions to Payment Policies for 2008 – Under Arrangements
Recently, hospitals and physicians have sought alternatives to traditional joint ventures as the reimbursement environment continues to contract. One of these alternatives has been the development of the “under arrangement” model.....Click here for entire Alert

CMS Proposes Reimbursement Limitations for ESA Therapy in Cancer Patients
(PYA Alert dated May 31, 2007)
On May 14th, CMS announced its proposal to limit coverage of ESA treatment to certain cancers and related neoplastic conditions, either because of harmful ESA effects on the beneficiaries’ underlying disease,....Click here for entire Alert

Proposed Rule for Inpatient Prospective Payment System (IPPS) Includes New MS-DRG's
(PYA Alert dated April 27, 2007)
On April 13, 2007, CMS displayed an advance copy of the proposed rule for Medicare's IPPS effective for discharges on or after October 1, 2007. The proposed rule contained the annual updates to IPPS rates and wage index....Click here for entire Alert

Is your organization ready for the operational and financial impact of the proposed severity-adjusted DRG system?
(PYA Alert dated April 23, 2007)
CMS continues to plan toward transition to severity-adjusted DRGs in the near future. What will this mean for your organization and are you preparing now for this transition?...Click here for entire Alert

Are Your Hospital's Standing Physician Order Forms Contributing to Incorrect Assignment of Patient Status on Admission?
(PYA Alert dated April 18, 2007)
The CMS Intermediary Manual Part 3, Chapter II, section 3112.8, requires the physician’s admission order to clearly state the level of care the patient requires, e.g., “admission to inpatient status” or “admission to observation status”...Click here for entire Alert

Transforming Patient Access
(PYA Alert dated April 17, 2007)
The healthcare revenue cycle can be a vehicle for implementing vast performance improvements. As you look to enhance the revenue cycle, addressing issues in the first component of the cycle–patient access–can lead to dramatic and sustainable returns...Click here for entire Alert

Are You Struggling with Drug Administration in 2007?
(PYA Alert dated April 6, 2007)
Major changes were implemented in 2007 for coding and billing of drug injections and infusions. Key to these changes, we have reverted to reporting of drug administration charges through CPT codes...Click here for entire Alert

Timeline for Final Rule for Stark II Extended
(PYA Alert dated April 5, 2007)
Please see the following excerpt from the March 23, 2007 Federal Register...Click here for entire Alert

Continuing the Shift to Consumer-driven Healthcare... CMS to Provide Physician Quality Measures to Medicare Beneficiaries
(PYA Alert dated March 15, 2007)
In February 2007, Centers for Medicare and Medicaid Services (CMS) announced an initiative that will provide performance information to beneficiaries. Through its partnership with Delmarva Foundation Medical Care and four regional collaboratives...Click here for entire Alert

Upcoming OIG Scrutiny for Hospital-based Outpatient Rehabilitation Services
(PYA Alert dated March 9, 2007)
Is your facility affected by the January letter issued by the Office of Inspector General Program Integrity Unit (PI) of the Georgia Department of Community Health (DCH)? If so,...Click here for entire Alert

Landmark Change to Verbal Orders in the Conditions of Participation
(PYA Alert dated February 21, 2007)
How long has the battle been waged with physicians over countersignature of their own verbal orders, in accordance with longstanding CMS’s Conditions on Participation (CoP)...Click here for entire Alert

Emergency Room Call Coverage Deferred Compensation Planning Strategy
(PYA Alert dated February 2, 2007)
Hospitals increasingly struggle with the challenge of securing emergency room call coverage and funding an adequate level of compensation for the physicians that agree to provide such coverage...Click here for entire Alert

Recent Conditions of Participation ("CoP") Changes to History and Physical ("H&P") Requirements
(PYA Alert dated January 30, 2007)
The final CMS Conditions of Participation ("CoP") regulation published in the November 27 Federal Register offers increased flexibility for an often challenging quality monitor, timeliness of history and physical ("H&P") reports...Click here for entire Alert

Office of Inspector General Publishes the 2007 OIG Work Plan
(PYA Alert dated January 16, 2007)
If you haven’t yet tuned into the 2007 OIG Work Plan, start bending your organization’s ear to ensure awareness. Out with the old and in with the new? Not quite...Click here for entire Alert

Revised Interagency Policy Statement on the Allowance for Loan and Lease Losses ("ALLL")
(PYA Alert dated December 20, 2006)
Recently, the federal banking agencies, including the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit...Click here for entire Alert

Coumadin Clinic Codes New for 2007
(PYA Alert dated December 12, 2006)
The American Medical Association has established two (2) new 2007 CPT E/M codes for the care, management and monitoring of patients on Coumadin therapy...Click here for entire Alert

Final Rule for Inpatient Prospective Payment System (IPPS) Includes Reforms
(PYA Alert dated October 18, 2006)
On August 1, 2006, the CMS displayed an advance copy of the final rule for Medicare's IPPS effective for discharges on or after October 1, 2006. This final rule stated certain inpatient payment methodologies have been reformed...Click here for entire Alert

Surprise! It's a Carrier Review!
(PYA Alert dated October 6, 2006)
A review of your coding and billing practices may be in the works by your carrier. Its important to understanding the carrier review processes and how a review may be triggered...Click here for entire Alert

New Safe Harbors for the Provision of Electronic Prescribing and Health Record Technology
(PYA Alert dated September 13, 2006)
Good news for those wanting to transition to electronic medical records! Effective October 2006, two new safe harbors under the Federal anti-kickback statute have been established to allow...Click here for entire Alert

Imaging Cuts - How Will Your Practice Respond?
(PYA Alert dated August 25, 2006)
A dramatic cut to the Medicare physician fee schedule will be fully effective beginning January 1, 2007. This cut involves two major provisions, both of which are a result of the Deficit Reduction Act of 2005 (DRA). (S. 1932, Sec. 5102). Although reimbursement for imaging services accounts...Click here for entire Alert

Deficit Reduction Act of 2005 ("DRA")
(PYA Alert dated August 14, 2006)
A new federal act, signed in February 2006, is going into effect on January 1, 2007, which imposes new requirements on mid-sized to large Medicaid providers: The federal Deficit Reduction Act of 2005 (“DRA”)...Click here for entire Alert

Is your organization aligned with upcoming state Medicaid program compliance initiatives?
(PYA Alert dated July 20, 2006)
Doug Colburn, Inspector General for the Georgia Department of Community Health, spoke before a June 9, 2006 Compliance Officer Roundtable meeting at the Georgia Hospital Association to lend insights. Of topics discussed...Click here for entire Alert

Hospital/Physician Relations: How do you know if your organization is paying fair market value for services rendered?
(PYA Alert dated June 28, 2006)
The term “fair market value” has become increasingly important within the healthcare industry, particularly after the Stark II Phase II regulations were finalized...Click here for entire Alert

CMS Issues Additional Information Regarding Consultations
(PYA Alert dated June 22, 2006)
The Centers for Medicare and Medicaid Services (CMS) caused a stir when they issued Transmittal 788 on December 20, 2005 regarding consultations.  The transmittal specifies documentation requirements...Click here for entire Alert

October 1, 2006 Brings Over 200 New ICD-9-CM Diagnosis Codes
(PYA Alert dated May 16, 2006)
New, revised and deleted ICD-9-CM diagnosis codes have been released by the Centers for Medicare and Medicaid Services (CMS)...Click here for entire Alert

Challenges for Non-profit Hospitals for 2006 and Beyond
(PYA Alert dated March 31, 2006)
For non-profit hospitals nationwide, this year could be the start of increased examination into tax-exempt status and provisions for charity care. As an example...Click here for entire Alert

AMA Publishes Corrections to CPT 2006
(PYA Alert dated March 27, 2006)
The American Medical Association (AMA) has identified inaccuracies in their CPT 2006 coding book. This affects codes found in...Click here for entire Alert

CPT Consultation Code Changes: Effective January 1, 2006
(PYA Alert dated February 2, 2006)
The Follow-Up Inpatient Consultation codes (99261-99263) and the Confirmatory Consultation codes (99271-99275) have been deleted from CPT for 2006. Beginning January 1, 2006...Click here for entire Alert

Documentation's Impact on Pay for Performance
(PYA Alert dated August 3, 2005)
Remember when you played “Leapfrog” with your friends and “HealthGrades” showed how well you performed in PE class? What about those extra dollars (Pay for Performance)...Click here for entire Alert

Stark II - Are You in Compliance?
(PYA Alert dated April 6, 2005)
CMS issued its "Phase II" Stark Regulations on March 26, 2004 with an effective date of July 26, 2004. Unlike the Medicare Anti-Kickback Statute...Click here for entire Alert

Medicare Issues Clarification and Guidance for Diabetes Screening Tests
(PYA Alert dated February 16, 2005)
Medicare beneficiaries at risk for diabetes are eligible for a new screening benefit effective January 1, 2005, as provided by Section 613 of the Medicare Prescription...Click here for entire Alert