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informal survey of third-party billing contracts. notably, not a single contract (other than the ones we drafted) included a fail-safe provision that permits a billing company to terminate an agreement if a provider is suspended from the medicare program. Keep in mind, a physician or other provider who is placed on suspension by medicare can continue to treat medicare patients. however, during this period, any monies due to the provider will be placed in an account controlled by medicare until a medicare contractor (typically a Zone Program integrity contractor, or ZPic) can complete a post-payment audit of the physician’s medicare claims to determine how much of an alleged overpayment exists. the heart of the problem lies in the fact that a suspension action almost always lasts at least six months and typically continues as long as a year. during this period, no medicare monies will be paid to the provider. therefore, no monies will flow to the billing company unless a flat-fee agreement or a per-claim agreement is in place. We strongly recommend that all third-party billing companies incorporate A More Secure Way to store files 20 hbma billing • november.december.2013 a provision into their agreement which addresses this potential problem. • assess risks of “Prepayment review” actions: as the centers for medicare and medicaid services (cms) and its contractors continue to move away from a “pay and chase” approach towards claims, the number of physicians and other providers placed on “Prepayment review” will continue to rise. the risk of being placed on prepayment review is especially high now that both ZPics and racs will be performing these program integrity actions on behalf of cms. Physicians and other providers should carefully examine their documentation, coding, and billing practices. do your claims qualify for coverage and payment? if a physician’s practice is placed on prepayment review, it is essential that he or she diligently work to identify any concerns that a medicare contractor may have with respect to the physician’s claims. Physicians and other providers should not merely try to avoid the issue (by, for example, holding claims until the payment (The Good, the Bad, and the Ugly continued) 500+ medical billing o ces nationwide use eBridge’s HIPAA-compliant, secure cloud-based document management system to streamline operations, save money, and reclaim space. t Provider scanning and retrieval t E! ortless work queue management t Quick and easy batch scanning t Compliant audit trails to track user access t Full-text keyword searches for ultra-fast retrieval Call 813-387-3870 today for a demo. Because your business is about more than just paper. www.eBridge.com 813-387-3870 LHaywood@eBridge.com


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