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Published February 19, 2021

PYA Principal Quoted in HCCA Article on Behavioral Health Billing Compliance

PYA Principal Denise Hall-Gaulin is quoted in a recently published Report on Medicare Compliance, covering the compliance risks related to billing for psychiatric outpatient services, specifically Intensive Outpatient and Partial Hospitalization service offerings. The article, “Palomar Health Settles CMP Case on Intensive Outpatient Psych Services,” covers the Health and Human Services (HHS) Office of the Inspector General (OIG) case against the hospital. The case alleges that Palomar was billing for intensive outpatient behavioral health therapy that wasn’t medically necessary. According to the article, there have been other behavioral health settlements with the OIG. Denise goes on to say that intensive outpatient psychiatric or partial hospitalization services are billed in an outpatient status, but are not the same type of therapy offered in outpatient mental health services. 

Article Excerpt:

Intensive outpatient psychiatric services and partial hospitalization are designed to keep patients out of inpatient beds, but they’re intended to be “episodic,” [Denise] Hall-Gaulin said. “One of the biggest problems I have seen with this is people set up the programs and never discharge them to an outpatient setting. There’s a misunderstanding about the purpose. It’s not supposed to be long term.”

Read the full article on the Health Care Compliance Association’s (HCCA) COSMOS, an online platform for easy access to the latest compliance information.

If you would like more information on billing compliance or for assistance with any matter involving coding, medical necessity, and compliance, valuation, or strategy and integration, contact one of our PYA executives below at (800) 270-9629.

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