Monthly Newsletter

September 2021 Monthly Newsletter

ONC Hosting FREE Information Blocking Webinar for Clinicians

What Healthcare Providers Need to Know About Information Sharing & the Information Blocking Regulation

Register for the September 14, 2021 at 1PM ET for the first in a series of clinician-focused webinars on the information blocking regulation. Experts will explain how the Office of the National Coordinator for Health Information Technology (ONC) supports secure, appropriate sharing of electronic health information and how information sharing leads to more affordable and equitable care and improved care quality.  Hear answers to questions such as:

  • What is information blocking and why should I care?
  • Why is information sharing so important?
  • What information needs to be shared and with whom?
  • What are the allowable exceptions and when do they apply?

Click Here to Register for this Event. If you’re unable to join the live presentation, you can still register to receive a link to access a recording of the webcast.

Healthcare Apps and Data Privacy/Security Risks

Susan Walberg, JD MPA CHC is a health care attorney and AIHC affiliate.  Her recent article on health care apps is worth a moment of your time.  As Susan states, whether you are a consumer who uses such apps, or a provider who wants to develop an app for patients to use, it’s important to understand some of the privacy and security risks that may accompany the use of such tools, and what to watch out for, especially “free” apps. 

Apps as Mobile Devices - There is one type of application which is actually considered by the Food and Drug Administration (FDA) to be a medical device, in addition to being covered under HIPAA (because they are provided in conjunction with healthcare services). Those are the apps that are intended to be used ‘for the diagnosis of disease or other conditions, or the cure, mitigation, treatment, or prevention of disease, or is intended to affect the structure or any function of the body of man’ under section 201(h) of the Food, Drug, and Cosmetic Act.

In general, if the purpose or function of the app is to assist in performing a medical device function, it will be treated as a medical device under the FDA. For instance, if the app can be run on a smart phone or other hand-held device and analyzes and interprets EKG waveforms to monitor cardiac irregularities, it would be considered analogous to those software programs that perform the same function and are otherwise regulated as a medical device.  Although the FDA purview is not privacy or data security, the FDA jurisdiction is noteworthy in terms of regulatory oversight. For purposes of HIPAA, these devices would typically be subject to the Privacy and Security rules as they are used in conjunction with your provider or insurance company, as discussed above.  Read the full article which is written for both health care consumers and providers!

Investigation Called Operation “Happy Clickers”

Telemedicine Fraud Scheme Investigations


The Department of Justice (DOJ) announced an ongoing investigation dubbed Operation “Happy Clickers” on August 24, 2021 which is a series of criminal and civil enforcement actions taken as part of a joint-agency healthcare fraud operation.  Fraud losses to the Medicare Program to date exceed $7.3 million.

How the scheme works - the marketers called Medicare beneficiaries, often through overseas call centers, soliciting them for medically unnecessary braces and cancer genetic testing for screening purposes.  The marketers, typically working through locum tenens companies, paid medical practitioners to purportedly review and sign these orders under the guise of telemedicine and then sold those signed orders to the owners of the DME supply companies and laboratories in violation of the federal anti-kickback statute.

Operation “Happy Clickers” is an ongoing initiative by HHS-OIG, the FBI, and the U.S. Attorney’s Office for the Western District of Michigan.  Read more about this case.

Psychotherapy in Nursing Homes & LTC

Documenting medical necessity is required to avoid violation of the False Claims Act.  Compliance to assigning appropriate billing codes is also critical to avoid upcoding. There is no exception, even when billing time, when it comes to behavioral health providers, as seen in a Georgia qui tam case.  The whistleblower was a former employee of Carenow Services, a psychotherapy services provider.   

“Carenow Services allegedly exploited not only its access to Federal health care dollars, but also its relationship with nursing facility residents in need of psychological services,” said Derrick L. Jackson, Special Agent in Charge with the Department of Health and Human Services Office of Inspector General. $2 million is being paid by Carenow and its CEO Leen Karun to settle this False Claims Act case. The settlement includes credit to Carenow for their cooperation with government officials during the investigation, pursuant to the Justice Manual. 

Read more about this case.  Learn more about the Justice Manual, False Claims Act and compliance – Online or in-person Class.

Public Health Emergency (PHE) and Telehealth

The Centers for Medicare & Medicaid Services (CMS) created the Comparative Billing Reports or “CBRs” as an education tool for providers.  This report reflects a specific provider’s billing and/or prescribing patterns as compared to the provider’s peers within a service area. Each CBR is unique to a single provider, is disseminated only to that individual provider, and is not publicly available. Receiving a CBR is not an indication of or precursor to an audit, and it requires no response on a provider’s part.

Attend the CMS CBR Impact of the PHE on Telehealth WEBINAR on Wednesday, Sept 8th, 2021.  This session will review the Comparative Billing Report (CBR) 202108 Impact of the Public Health Emergency (PHE) on Telehealth.  Click Here to go to the official CBR webpage where you can register and download handouts.

CMS Expands Medicare Payments for At-Home COVID-19 Vaccinations

To ensure Medicare beneficiaries who have difficulty leaving their homes or are otherwise hard-to-reach can receive the vaccination, health care providers can now receive additional payments for administering vaccines to multiple residents in one home setting or communal setting of a home. 

While many Medicare beneficiaries are able to receive a COVID-19 vaccine at a retail pharmacy or from a health care provider, some people have great difficulty leaving their homes or cannot easily access vaccination in these settings. These individuals are often at-risk patients who could require complex care if they contracted COVID-19 and needed to be hospitalized. To better serve this group, Medicare previously increased the total payment amount for at-home vaccination from approximately $40 to approximately $75 per vaccine dose, in certain circumstances.  Delivering COVID-19 vaccination to access-challenged and hard-to-reach individuals poses some unique challenges, such as ensuring appropriate vaccine storage temperatures, handling, and administration. Along with the CDC guidance, this announcement helps vaccine providers meet these challenges and successfully administer vaccinations.

Click Here for the CDC Guidance Vaccinating Homebound Persons With COVID-19 Vaccine.

For individuals who are underinsured, vaccine providers may submit claims for reimbursement for administering the COVID-19 vaccine through the COVID-19 Coverage Assistance Fund administered by HRSA after the claim to the individual’s health plan for payment has been denied or only partially paid.

For individuals who are uninsured, vaccine providers may submit claims for reimbursement for administering the COVID-19 vaccine to individuals without insurance through the Provider Relief Fund, administered by HRSA. Click Here for information on the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program.

More information on Medicare payment for COVID-19 vaccine administration – including a list of billing codes, payment allowances and effective dates Click Here for the Medicare COVID-19 Vaccine Shot Payment webpage.

Providers and the Illegal Distribution of Drug Explosion!

The Office of Inspector General (OIG) published an August 27, 2021 announcement which lists various enforcement actions just in the last part of August involving U.S. providers and health care fraud involving drugs. Is your organization conducting routine audits to detect and internally investigate high-risks? 

PA Sentenced to Federal Prison for 3 Years

William Soyke, age 68, of Hanover, Pennsylvania has been sentenced to 37 months in federal prison along with 3 years of supervised release for conspiracy to distribute and dispense oxycodone, fentanyl, methadone, and alprazolam outside the scope of professional practice and not for a legitimate medical purpose. Click Here for news release.

Doctor Sentenced to more than 15 Years in Prison for Unlawful Distribution of Medically Unnecessary Oxycodone

Dr. Emmanuel Lambrakis, age 74 of New York, wrote medically unnecessary prescriptions for thousands of oxycodone pills.  Lambrakis operated two medical clinics in Queens, New York, where he wrote numerous medically unnecessary prescriptions for large quantities of oxycodone in exchange for cash payments, typically charging $150 in cash for “patient visits”.  Lambrakis collected approximately more than $3 million in fees from his “patients.”  In addition to the prison term, he was sentenced to three years of supervised release, and ordered to forfeit $3,093,000, representing the amount he gained from issuing medically unnecessary oxycodone prescriptions. Click Here for news release.

$15 Million Paid to Resolve Fraud and Controlled Substances Allegations

Connections Community Support Programs, Inc. (“CCSP”), prior to bankruptcy, provided a variety of mental health and addiction treatment services at numerous locations throughout Delaware.  CCSP is paying $1,621,571, plus interest, to resolve claims that it violated the federal Controlled Substances Act by negligently failing to keep proper records of its use of controlled substances, including methadone and buprenorphine, in its treatment of patients with substance use disorders and by transferring controlled substances between locations without proper documentation.  They have also agreed to pay $13,757,520.60, plus interest, to resolve claims that they violated the False Claims Act by billing for mental health services performed by individuals whose professional qualifications did not allow them to bill Medicare or Medicaid for reimbursement and by billing Medicaid for mental health services using incorrect procedure codes for the person performing the service, resulting in higher payments than were permitted.  Click Here for news release.

Former Anesthesiologist/Pain Management Doctor Sentenced for Illegal Distribution of Drugs

Thomas Ranieri, age 68, of New Castle Pennsylvania has been sentenced in federal court for unlawfully prescribing and distributing controlled substances.  From January 2, 2013, to June 26, 2013, the defendant prescribed and distributed quantities of Schedule II controlled substances (i.e., Oxycodone, Fentanyl, and Opana ER) outside the usual course of professional practice and without a legitimate medical purpose. In total, the defendant pled guilty to fourteen distribution counts associated with his dispensing of approximately 1,100 doses of narcotics. Click Here for news release.


3 Live Training Events


Training Camp

October 6-7, 2021 Tampa, FL


Training Camp

October 20-21, 2021 Nashville, TN


Training Camp

October 26-27, 2021 Las Vegas, NV

Train & Certify Online as an Outpatient Clinical Appeals Specialist

Appeals Management

Earn your COCASSM (Certified Outpatient Clinical Appeals Specialist) credential online. No classes to attend but you do have access to qualified, experienced instructors on-demand. Most experienced working in outpatient Patient Financial Services, Revenue Cycle Management, Accounts Receivables, Medical Coding and/or Billing complete this training in 6-8 weeks, but you have 12 weeks (and more time you can purchase) to complete the course and an addition 3 months to certify.

Certification exam is taken safely online, timed at 3 hours, has 100 questions and scheduled with a professional remote Proctor.

Learn More - watch the video - register and start today!

Internal Forensic Auditor

Learn How to Conduct Internal Investigations

Earn your CIFHA (Certified Internal Forensic Healthcare Auditor) credential online.  Member Pay Only $995 (payment plans available).  Non-members pay $1,500.  Tuition includes all online training materials, mock and certification exam.

Certification exam is taken safely online with a trained, remote proctor timed at 3 hours.  Learn More - watch the video - register and start today!

Auditing for Compliance

Plan - Execute - Report - Corrective Action PERC

Earn your CHA (Certified Healthcare Auditor) credential online.  Member Pay Only $995 (payment plans available). Non-members pay $1,500.  Tuition includes all online training materials, mock and certification exam.

Certification exam is taken safely online with a trained, remote proctor timed at 3 hours.  Learn More - watch the video - register and start today!

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