Jeremy Miller’s Article on THE 60-DAY SWORD OF DAMOCLES [You’ve Got 60 Days to Pay Up- or Else!]

Consider the following scenarios involving medically necessary services for Medicare or Medicaid patients: (1) a medical group learns that its outside billing service has incorrectly used the physician’s office site of service code when billing Medicare for hospital consults; (2) an imaging center finds out it did not have adequate physician supervision when performing MRls using contrast media; (3) a physician discovers it was improper to mark up tests purchased at a discount from an outside lab; and (4) a hospital realizes it has failed to make annual CPI adjustments to the rent under a physician’s office lease.

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