OIG Reports on Questionable Billing for Mental Health Services

Posted by Salvatore G. Rotella Jr. on September 10, 2012
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As its title makes clear, the August 2012 report “Questionable Billing by Community Mental Health Centers” (the Report) by the U.S. Department of Health and Human Services Office of Inspector General (OIG) demonstrates its significant concern with fraud, waste, and abuse in Medicare payments for mental health services.  The OIG’s key findings include that in 2010, about 50% of community mental health centers (CMHCs) exhibited unusually high billing for at least one of nine so-called “questionable billing characteristics” in seeking reimbursement for partial hospitalization program (PHP) services; about 33% exhibited at least two of these characteristics.  Continue reading…

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OMG! DC Circuit Rules on PRTFs, CMS, IMDs, and FFP!

Posted by Salvatore G. Rotella Jr. on June 22, 2012
Medicaid / No Comments

The U.S. Court of Appeals for the D.C. Circuit recently held that federal Medicaid funding (FFP) is unavailable for any health care services, other than inpatient psychiatric services, provided to individuals under the age of 21 in a Psychiatric Residential Treatment Facility (PRTF). Virginia Dept. of Medical Assistance Services v. Sebelius, Nos. 11-5161 & 11-5242 (D.C. Cir. May 8, 2012). In reaching that conclusion, and tackling an area of health law with more than its fair share of acronyms, the Court rejected arguments by two state Medicaid programs that FFP should be broadly available for care in a PRTF. This is yet another turn in the long and winding PRTF saga. Continue reading…

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