General Question for the Week of November 4, 2019

General Compliance Question of the Week


What are the circumstances that the new CMS authorities may act on?


The Centers for Medicare & Medicaid Services (CMS) states that “The rule also includes other authorities that will effectively improve CMS’ fraud-fighting capabilities. Similar to the affiliations component, these authorities provide a basis for administrative action to revoke or deny, as applicable, Medicare enrollment if:

  • A provider or supplier circumvents program rules by coming back into the program or attempting to come back in, under a different name (e.g. the provider attempts to “reinvent” itself)
  • A provider or supplier bills for services/items from non-compliant locations
  • A provider or supplier exhibits a pattern or practice of abusive ordering or certifying of Medicare Part A or Part B items, services or drugs; or
  • A provider or supplier has an outstanding debt to CMS from an overpayment that was referred to the Treasury Department.”