Preparing for Government Audits: Atypical Antipsychotics

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Most people would agree that the Centers for Medicare & Medicaid Services (CMS) are justified in seeking to ensure that the long-term an acute care services they pay for are appropriate and meet federal standards. After all, ours is a rapidly aging population that is increasingly reliant on the Medicare/Medicaid system. From a purely budgetary standpoint, it makes perfect sense to put checks and balances in place to make sure the dollars are spent where they should be.

In 2010, CMS launched its Medicare Recovery Audit Contractors (RAC) program to help do exactly that—primarily, to review care provider billings to identify and recover overpayments and, to a lesser extent, identify and reimburse for underpayments. CMS reports that in fiscal year 2016 alone, the program had recouped $4.7 billion.

In the healthcare industry, new focus areas are being identified by the Office of Inspector General (OIG) and CMS on a regular basis, and these same focus areas can easily become the subject of investigation by the Department of Justice. Among the areas of focus most on the radar of our long-term care clients are atypical antipsychotic medications, hospice services, and physical therapy services. In this three-part series of white papers, we’ll take a look at each of these issues—examining how they came to be focus areas, what your organization needs to do to be in compliance with CMS standards, and what you can do now to prepare for, or respond to, audits. Read more

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