Message Digest

This message has been cross posted to the following eGroups: Behavioral Health Care Compliance and Auditing and Monitoring Compliance Network .
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I'm assisting a small facility (50 bed)  attain Medicare certification.  A specific challenge has come up related to meeting the CMS UR CoP's.  This faclity only has 2 physicians on staff.  (obviously there are COI issues.)   The CoP's state the UR comittee must be comprised of 2 physicians or have an agreement with an QIO.

I've not experienced a facilty with a QIO, we've always been able to do this in house.

Any ideas, resources or guidance for creating an effective UR program that will meet the CMS requirements?

Thanks
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PatrickWilderLCSW
Assoc VP Quality & Compliance
PSI
PortlandOR
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My agency received its first MIC audit letter back in May stating that we did not bill Tricare for a child in our residential program.  We responded within the time alloted explaining that we are not one of the handful of RTC's in the country that is certified to bill Tricare.  We did not hear anything from the contractor (HMS) for three months.  Two weeks ago, the amount of the original audit, just over $38,000, was deducted from our Medicaid check with no report or explanation.  In speaking with various contacts at HMS it sounds as if no one knew anything about Tricare certification for RTC's.  They in fact, didn't even know what an RTC was.  I have had to spend the past two weeks essentially "educating" HMS, and while they have admitted they were wrong and are working on a refund, we have yet to be reimbursed.  This leads me to a number of questions: 

Has anyone else had similar experiences?  There are only 40 Tricare certified RTC's, so I find it hard to believe this is the first time something like this has come up.

The MIC fact sheet CMS published in November 2009 states that Audit contractors will issue a report after each audit, which both the State and provider will have time to review and comment on.  Is there a specified time frame in which the provider is supposed to receive this report?  Can repayment be taken before the provider has had a chance to review the report and comment?

Has CMS set up any kind of system for providers to give feedback about the MIC's?  I looked on their website, but didn't see anything.

Thanks in advance--
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KristineNelsen
Compliance Officer
Alaska Children's Svcs
AnchorageAK
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This message has been cross posted to the following eGroups: Behavioral Health Care Compliance and Government city county state and other Network .
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I had a call the other day wanting to know if I had a policy for residential programs that would include how to handle the police showing up with an arrest warrant. I do not have one since we do not have residential programs, after some thought, I realize we should have one as well. Does anyone have one they would be willing to share? Thanks in advance.

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CathyGarreyCHC
Comp/Quality Assurance Mgr
McHenry Co Mental Hlth Board
Crystal LakeIL
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I have a request from a physician who recently attended a conference that sample drugs can now be sold from the physician's office (outpatient practice).   I searched the FDA site and from everything I read, that is explicitly prohibited.   I also found some case law from several years back where physicians pled guilty for selling sample drugs.   Are there any changes that anyone is aware of that would make this an allowable practice? 


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PhyllisWestRN
VP Compliance & Risk
Decalur General
DecaturAL
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Welcome to the Behavioral Health Care Compliance Discussion Group.  The purpose of the discussion group is to provide a means for those in behavioral health to share information about how new health care reform regulations are impacting providers, provide a forum for relaying what federal and state audits are targeting, the outcome of audits and how we can improve our voice at the state and national levels.

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CathyGarreyCHC
Comp/Quality Assurance Mgr
McHenry Co Mental Hlth Board
Crystal LakeIL
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