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Over the past several months the Office of Inspector General (OIG) and Center for Medicare and Medicaid Services (CMS) have issued reports emphasizing that those providers who receive high levels of payments and those who do not comply with educational efforts should be targeted for review and sanctions.

The OIG recently issued a report recommending that CMS focus efforts on identifying a certain cumulative payment threshold and closely monitor and audit providers at or above that threshold.  CMS also issued a Change Request to the Medicare Program Benefit Integrity Manual, detailing that Medicare Administrative Contractors should address those providers who do not change inappropriate or illegal behavior associated with filing claims with the federal health care programs despite education and training by pursuing any applicable sanctions, including civil monetary penalties and exclusion from the Medicare program. In another effort to reduce fraud and promote transparencythe Obama administration issued a policy effective March 18th whereby individuals can request Medicare payment information for providers under the Freedom of Information Act.

The efforts by CMS and the OIG emphasize the need for providers to ensure that they have appropriate and comprehensive documentation associated with all of the claims filed with the federal health care programs.

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