Audit Today, Revocation Tomorrow?

Federal regulations grant the Centers for Medicare & Medicaid Services (CMS) the authority to revoke a healthcare provider's Medicare billing privileges for submitting claims for services that could not have been provided on the purported date of service, such as billing for deceased beneficiaries. A Final Rule became effective in 2015 extending the authority of CMS to revoke a provider's billing privileges if CMS determines that the provider has a pattern or practice of billing for services that do not meet Medicare requirements. Violations under the Final Rule include situations in which a provider regularly and repeatedly submits claims for medically unnecessary services. While historically a provider's noncompliance exposed the provider to overpayment refund demands resulting from CMS audit activity, this new revocation authority emphasizes an even greater need for providers to ensure their billing and documentation practices are in compliance with Medicare reimbursement requirements.