False and Nonsensical Medical Records Reportedly Not Unusual

Poorly designed EHRs likely the culprit for the proliferation of false medical records.

Last week Talk Ten Tuesdays listener “Robert” discussed during the weekly Internet broadcast the fact that a physical examination documented in his medical record for a recent hospital visit was false, indicating that the physician never performed an exam.

Sadly, this is not a startling revelation or a unique occurrence.

Coders and auditors see false or nonsense documentation every single day. The difference in Robert’s story is that he is knowledgeable in coding and billing and had the expertise to evaluate the documentation. Most patients never see their medical record, and thus it is highly likely that innumerable cases of false documentation go undetected. More importantly, unless there is a noticeable error or other warning flag, coders and auditors may have no way to see below the tip of the iceberg.

This proliferation of false documentation is largely attributable to poorly designed electronic health records and similar templated documentation systems. The need for providers to document extensive notes to incorporate all the “quality” information and other payment methodology requirements has resulted in what is not-very-fondly referred to as “note bloat.” When we add in the Centers for Medicare & Medicaid Services (CMS) and CPT® Evaluation and Management (E/M) service documentation requirements, there is a lot of required information that may or may not be relevant to support a specific level of service.

The fact is that documentation takes an ever-increasing amount of time physicians often do not have. This results in attempts to streamline the process, and those solutions have the potential to create the exact opposite of the desired outcome. A very popular solution is the one-click methodology that creates a standard, pre-filled document. The thought is that the provider will edit and correct that standard to accurately reflect actual patient encounters. Unfortunately, but not surprisingly, that often does not happen.

As a result, we see patients suddenly re-growing limbs or anatomical parts they don’t have, a “normal” exam of a noticeable injury, no exam of the chief complaint, etc. In some cases, faulty editing makes a bad situation worse. For example, I just read a medical record for which the patient’s head exam included bowel tones. In many cases, the physical exam is in direct contradiction with the rest of the encounter documentation. Those are the obvious errors that are easily identified.

In Robert’s case, without a patient complaint, it is probable that the false documentation would not have been identified. However, at least Robert was really there that day. Cases of complete notes being produced when no patient visit occurred are also not uncommon. The practice of pre-populating the scheduled patient visits to edit later has also gained traction. If due diligence is not vigorously exercised, those completely false notes are billed.

A reasonable recommendation for Robert’s case was to contact the provider and/or compliance officer. Sadly, we have seen cases in which even that is ignored, and no corrections to the false records were made. In some cases, even the payer fraud units failed to respond, choosing to believe the medical record over the patient.

We know that the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) and CMS have been focused on these issues for quite some time. Interestingly, CMS in the proposed physician fee schedule requested input on revamping E/M documentation requirements, including the possibility of eliminating them.

The fact is that false documentation has the potential to cause great patient harm. More is not necessarily better. Documentation really should be customized, accurate, and useful for clinical care.

Until the focus is on what really matters, we have a huge problem requiring a solution.

Program Note: For more information on this subject listen to Holly Louie today on Talk Ten Tuesdays at 10 a.m. ET. Register to listen.

Holly Louie, RN, CHBME, is the compliance officer for Practice Management Inc. and the 2016 HBMA president.

Payment Matters

Will CMS Consider Your Institution to Be a Hospital? Guidance on the “Primarily Engaged In” Standard

Thomas W. Coons, 410.862.1189tcoons@bakerdonelson.com

Recent guidance from CMS suggests that some hospitals, and particularly specialty hospitals that provide mostly outpatient care, may soon find themselves the focus of surveyors’ scrutiny. In early September, CMS issued guidance addressing what it means to be “primarily engaged in” the provision of inpatient services, a Medicare requirement for a facility’s payment as a hospital. That guidance is found in a memorandum to State Survey Agency Directors and in the revisions to the State Operations Manual, and it highlights many of the considerations that CMS and its surveyors will take into account in determining whether a facility qualifies as a Medicare “hospital.”

OIG Finds Continued Procedural Errors in Hospital Outlier Payment Reconciliations

Bryna Shmerling, 202.326.5012, bshmerling@bakerdonelson.com Reviewed by Leslie Demaree Goldsmith, 410.862.1133, lgoldsmith@bakerdonelson.com

The U.S. Department of Health and Human Services, Office of Inspector General (OIG) recently released a Report concluding that there are vulnerabilities in the process of reconciling Medicare hospital outlier payments. The report summarizes the results of a previous 2012 OIG audit of outlier reconciliations, in which the OIG reviewed outlier payment data submitted to CMS by a sample of Medicare contractors during the audit period of October 1, 2003 through December 31, 2008, and a series of subsequent reviews of outlier payments. The OIG looked into whether (1) “Medicare contractors had referred qualified cost reports to CMS for reconciliation in accordance with Federal guidelines” and (2) “outlier payments associated with qualifying cost reports had been reconciled.” As discussed in more detail below, the OIG indicated that there are still vulnerabilities in Medicare hospital outlier payments – within CMS and by the Medicare contractors – and issued recommendations to remedy the vulnerabilities.

OIG Finds Acute Care Hospitals Improperly Billed for Outpatient Services Provided to Inpatients of Other Hospitals

Matthew F. Smith, 615.726.5560, msmith@bakerdonelson.com Reviewed by Leslie Demaree Goldsmith, 410.862.1133, lgoldsmith@bakerdonelson.com

Acute care hospitals that provide Medicare outpatient services to inpatients of other hospitals should be billing and collecting payment from the other inpatient hospitals and not from Medicare.

In a Report released on September 18, the Office of the Inspector General (OIG) found CMS had inappropriately paid more than $51.6 million between January 2013 and August 2016 for outpatient services acute care hospitals provided to Medicare beneficiaries who were inpatients at facilities other than acute care hospitals. The Report examined four types of non-acute care hospitals: (1) long term care hospitals; (2) inpatient rehabilitation facilities; (3) inpatient psychiatric facilities; and (4) critical access hospitals. In addition to payments from Medicare, the acute care hospitals collected $14.4 million in deductible and co-insurance amounts for these services from Medicare beneficiaries. While the Report noted the possibility that the acute care hospitals received payment from both Medicare and an under arrangement contract, the OIG did not verify whether the inpatient facilities paid the acute care facilities for the services rendered or if the inpatient facilities included the outpatient services on their Part A claims.


October Washington, D.C. Update

With never a dull moment in Washington, D.C., the past month has proven that anything and everything is possible. After repeated attempts to repeal the Affordable Care Act (ACA), most observers had written off this partisan effort. Yet unexpectedly in mid-September, Senate Republicans made another ultimately unsuccessful attempt at repealing the ACA.

In other surprising news this month, the White House, without consulting with congressional Republicans, reached an agreement with congressional Democrats to extend fiscal year 2017 (FY17) spending levels and suspend the debt ceiling for three months. The deal was reportedly reached during an Oval Office meeting with House and Senate congressional leadership when President Trump unexpectedly sided with “Chuck and Nancy,” (Senate Minority Leader Chuck Schumer (D-NY) and House Minority Leader Nancy Pelosi (D-CA)) ignoring advice from House Speaker Paul Ryan (R-WI) and Senate Majority Leader Mitch McConnell (R-KY) that the GOP maintain a united front and push for Democratic concessions, including extending the debt limit until after the 2018 elections.

Looking forward, Congress faces a full calendar for October and November, including a new December 8 deadline for FY18 appropriations measures and an extension of the National Flood Insurance Program, as well as reauthorization of the Children’s Health Insurance Program (CHIP). Add to that agenda consideration of the Administration’s $29 billion appropriations request for recovery efforts related to recent hurricanes and wildfires (including Hurricane Maria’s impact on Puerto Rico), a potential bipartisan ACA market stabilization measure, and congressional Republicans’ desire to move forward with tax reform.

In this month’s Washington, D.C. Update, we examine:

Please feel free to reach out for additional information on these topics or other issues of importance.

Sheila Burke
Chair, Government Relations and Public Policy
Baker Donelson

White House Reaches Deal with Congressional Democrats to Keep Government Open and Suspend Debt Limit Until December

President Trump came to an agreement with congressional Democrats to extend FY17 federal appropriations and suspend the debt limit until December 8. The deal, which took congressional Republicans by surprise, was paired with a federal emergency appropriation for hurricane relief in the southeastern United States and passed the Senate by a vote of 80 to 17 and the House by a vote of 316 to 90 with all dissenting votes coming from Republican members. The three-month duration of the agreement, which opened a significant rift between Republican congressional leadership and the White House, gives Congress the rest of the fall to come to some sort of agreement over FY18 appropriations and the debt ceiling…

Congressional Republicans and White House Release Outline of Tax Reform Proposal

On September 27, the White House and its allies on Capitol Hill released the outline of their long-promised tax reform proposal. Generally, the outline seeks to create three individual income tax rates (12, 25, and 35 percent), eliminate many personal exemptions and deductions, lower the corporate tax rate to 20 percent, and implement a territorial tax system. The plan is primarily based on House Speaker Ryan’s “A Better Way” with the exception of the Border Adjustment Tax, which was not included. The proposal was only an outline and much of the plan will need to be worked out by the tax-writing committees in the House and Senate. Look for the debate over tax reform to be intense as congressional Republicans attempt to move the measure through the streamlined reconciliation process over the coming months…

Graham-Cassidy Falters; Bipartisan Talks Restart on Market Stabilization

Following defections from Senators Rand Paul (R-KY), John McCain (R-AZ), and Susan Collins (R-ME), Senate Republican leaders announced on September 26 that they did not have the votes for the Graham-Cassidy plan – the last attempt to push ACA repeal on a partisan vote before the Fiscal Year (FY) 2017 Budget Reconciliation expired on September 30. After initial talks halted due to the Graham-Cassidy push, Senate Health, Education, Labor and Pensions (HELP) Committee Chair Lamar Alexander (R-TN) and Ranking Member Patty Murray (D-WA) reportedly restarted negotiations to find consensus on a limited bipartisan stabilization plan for the individual market. A key sticking point in the debate is the level of state flexibility to waive ACA insurance regulations. Even if a deal were reached, Senate Republicans would need to overcome resistance from conservatives and skeptical House Republicans to achieve passage…

HHS Secretary Tom Price Resigns and the Search Begins for Replacement

Department of Health and Human Services (HHS) Secretary Tom Price resigned on September 29, following the collapse of Republicans’ efforts to repeal-and-replace the Affordable Care Act (ACA) and revelations that he spent more than $1 million on charter and military airplane travel at taxpayers’ expense. Price’s resignation has significant implications for HHS’s regulatory priorities, including enforcement of the ACA, regulatory flexibility on physician practices and the broader health care industry, efforts to combat opioid abuse and childhood obesity, and other HHS initiatives…

Federal Funding for CHIP Expires, Pending Congressional Reauthorization

Federal funding for the Children’s Health Insurance Program (CHIP) – which covers nearly nine million children nationwide at a total cost of approximately $14 billion per year – expired on September 30 as congressional action was sidelined by the focus on Republicans’ ACA repeal-and-replace efforts. On October 4, the Senate Finance and House Energy and Commerce Committees held their respective markups and advanced legislation for a five-year CHIP reauthorization. Congress is seeking to quickly pass an extension of CHIP funding this fall before states run out of money and are forced to reduce coverage, but reaching agreement on fiscal offsets for the legislation is likely to prove contentious…

Trump Administration Broadens Employer Exemption from ACA’s Contraceptive Coverage Requirements

On October 6, the Trump Administration issued two new interim final rules that significantly expand exemptions for employers to the ACA’s requirements to provide free contraceptive coverage. The new regulations, effective immediately, allow exemptions for 1) any employer or university with a health plan with objections to contraception based on religious beliefs, and 2) any non-profit or closely-held for-profit employer with moral objections. These regulations represent a significant departure from the previous standard, under which exemptions were limited to closely-held employers’ religious beliefs only (in addition to churches and some religious organizations that have always been exempt). Under the new interim final rules, many more employers may elect to withhold no-cost contraceptive coverage from their health plans…

Trump Executive Order Expected to Expand Association Health Plans and Short-Term Coverage

President Trump is expected to issue an executive order in the coming days that would direct federal agencies to expand access to association health plans (AHPs), which would be exempt from the ACA’s coverage requirements and eligible to be sold across state lines. The executive order would also expand access to short-term health plans, previously limited to 90 days, by allowing these plans to be purchased for up to a year. Expanding access to AHPs and short-term insurance plans would likely create cheaper, less comprehensive insurance options. However, this new policy may also encourage adverse selection that could increase premiums on the individual market if healthier consumers flock to these plans, leaving behind only sicker, more expensive consumers purchasing comprehensive coverage through the ACA’s insurance exchanges…

Lawmakers Approve a Six-Month Extension of FAA Authorization

On September 28, Congress approved a six-month extension to the Federal Aviation Administration (FAA) authorization, heading off a partial shutdown of the FAA. Expect negotiations over House Transportation and Infrastructure Chairman Bill Schuster’s (R-PA) proposal to spin off the FAA’s Air Traffic Control to a non-profit entity to continue into the spring. Congress now has until the end of March 2018 to come up with a solution to the stalemate or pass another short-term extension…

HBMA Government Relations Committee Annual Federal Advocacy Trip Update

The HBMA Government Relations Committee held its annual Federal Advocacy Trip June 20 – 22, 2017. This visit featured a day of meetings at the Centers for Medicare and Medicaid Services (CMS) headquarters in Baltimore, Maryland, as well as a day of meetings in Washington, D.C., split between a visit to Capitol Hill and a roundtable discussion with fellow industry stakeholders.

The Government Relations Committee 2017 Federal Advocacy Trip was an incredible success. Each year, these meetings offer a unique opportunity to discuss important policy issues that affect how the healthcare revenue cycle management (RCM) industry interacts with the Medicare program on a day-to-day operational level. They also include discussions of broader and more long-term topics as well.

For HBMA, these meetings are an opportunity not only to ask for changes to Medicare policy, but also to establish our organization as a resource to policy makers. Participating in these annual meetings for more than a decade, HBMA has made great strides in how we serve as a resource to policy makers.

Download and view the full update to learn more about the HBMA Government Relations Committee 2017 Federal Advocacy Trip

GDPR Goes into Effect Next Year; Is Your Privacy Program Ready?

By Jason R. Edgecombe, CIPP/US

You and your company may be located in the United States, but if any of your employees or customers are citizens of European Union (EU) member states, the EU will soon have a say in the collection, processing, storage, transfer, and protection of their personal information.

The General Data Protection Regulation (GDPR) was enacted by the EU Parliament and Council in April 2016 and will become effective May 25, 2018.

Unlike the United States, where a patchwork of privacy laws regulate different industries, the GDPR will be a comprehensive privacy law that governs any entity that collects or processes the personal data of any citizen of the 28 EU member states.

Critically for U.S. firms, the GDPR embraces an “extra territorial” approach, creating jurisdiction based on digital presence in the EU without reference to physical activity. Thus, the EU will enforce the GDPR’s requirements on any entity that

  • offers goods or services to the EU, or
  • monitors behavior of EU citizens,

irrespective of that entity’s lack of physical presence in the EU. For purposes of the GDPR, not having a “brick-and-mortar” presence in Europe will no longer be a defense for entities that interact with EU citizens and collect or process their data. Sanctions for violations can be steep, with EU regulators permitted to impose a financial penalty of up to four percent of a company’s global revenue.

Accordingly, it is vital that U.S.-based companies make a determination now as to whether their business activities will subject them to the GDPR’s requirements and to begin making appropriate preparations.

Offering Goods and Services

Given the global reach of the Internet – where anyone in the world can access your business’s products without being marketed to directly – determining whether you are “offering” your goods and services to the EU will be a critical undertaking.

Fortunately, the GDPR acknowledges that simply because a website can be accessed by EU residents does not mean that the site’s host “envisaged” a business relationship with the EU. But at what point the scales tip will be fact specific; regulators will look at issues such as whether a site is available in a non-native language, accepts Euro or other EU member state currencies, or otherwise appears to target residents of the EU explicitly. If so, the proprietor will need to be compliant with GDPR or start taking steps now to unwind its EU offerings.

Nevertheless, even businesses that do not target EU customers still might find themselves in the GDPR’s ambit if they are monitoring the Internet activities of EU residents.

Monitoring Behavior

The use of browser cookies is ubiquitous in modern e-commerce. While session cookies probably won’t run afoul of any regulations, the use of persistent cookies to track an EU user’s activities on the Internet arguably will be regulated by the GDPR. Moreover, as EU member states are beginning to view IP addresses as personally identifiable information in a way that U.S. courts and regulators have not, logging the IP addresses of EU residents also may constitute monitoring activity.

Suffice to say, there are a number of regular business activities that can pull an American company into the orbit of the GDPR, and with just over seven months until it becomes effective, now is the time to begin either winding down potentially offending actions or planning for compliance.

A High-Level Look at GDPR Compliance

Substantively, the GDPR places a number of compliance obligations on covered entities, with the following among the most critical:

  • Privacy Impact Assessment (PIA): A PIA will be a mandatory prerequisite before processing personal data. This documentation will need to be robust, especially if operations are likely to present higher privacy risks to individuals.
  • Expanded Personal Data: “Personal data” under the GDPR is more than what U.S. regulators typically define as “personally identifiable information.” Under the GDPR, personal data will also include information such as IP addresses, mobile device identifiers, biometric data, and geolocation tags.
  • Mandatory Data Protection Officer (DPO): Any entity that engages in “regular and systematic monitoring of data subjects on a large scale” or conducts large-scale processing of “special categories of personal data” (e.g., racial/ethnic origin, religious affiliation, or political opinions) must have a DPO with “expert knowledge of data protection law and practices.” While the DPO may have other responsibilities (and in smaller organizations, could be an outside counsel or consultant), the DPO must have a direct line of reporting to the “highest management level.”
  • Cybersecurity: Entities must “implement appropriate technical and organizational measures” for cybersecurity, taking into account “the state of the art and the costs of implementation” and “the nature, scope, context, and purposes of the processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.” Examples of such measures include pseudonymization, encryption, sufficient and secured backups, and an auditable and testable system to ensure the effectiveness of security protocols.
  • Breach Notification: “[A] breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data” requires notice to an EU supervisory authority “not later than 72 hours after having become aware of” the breach. Unlike most U.S. state data privacy laws, the GDPR requires notice irrespective of whether financial harm or fraud might result from the breach.
  • Opt-in Consent: Before a subject’s personal data can be processed, that individual must express consent that is “freely given, specific, informed and unambiguous.” Such consent must consist of “a statement or a clear affirmative action,” and “[s]ilence, pre-ticked boxes or inactivity” is not sufficient. Even more explicit personal consent is necessary for certain categories of sensitive data, and parental consent is necessary before processing a minor’s personal data.
  • Information Governance: Companies will have increased responsibility for knowing what information they control and how they must safeguard it. Individuals will have the “right to be forgotten,” which can present a complex set of issues for companies. They will also have the right to have better control over their personal data and to be informed in clear and plain language regarding a company’s privacy policies.

With GDPR enforcement becoming a reality in a matter of months, now is the time to assess whether it will affect your business activities. If you aren’t sure whether you hold data on European Union residents, the place to start is by updating your data map. Members of Baker Donelson’s Data Protection, Privacy, and Cybersecurity Team are ready to assist you in this process and help you decide what comes next.

Health Law Alert

OIG Work Plan – October 2017 Update

Ashley L. Thomas, 202.508.3429athomas@bakerdonelson.com Reviewed by William T. Mathias410.862.1067,    bmathias@bakerdonelson.com

The OIG added five new items to its Work Plan with its October 2017 monthly update. This is a decrease from the nine new items added to the Work Plan with the September 2017 update. (For more information on last month’s Work Plan update, see “OIG Work Plan – September 2017 Update“).

Last month, the Secretary of the Department of Health and Human Services (DHHS), Tom Price, resigned from his position as Secretary after news broke that he had used private charter flights and military aircraft at taxpayer expense. The OIG will review whether Secretary Price’s use of private charter flights was in compliance with applicable federal regulations and DHHS policies and procedures.

The rising cost of drugs for rare and complex conditions has become an issue of concern for state Medicaid programs. While high-cost specialty drugs are a small portion of the total of all drugs dispensed, they represent a disproportionate and growing share of total drug spending. Further complicating this issue is that there is no standard definition for specialty drugs, posing challenges in management of specialty drug costs. The OIG will examine how state Medicaid programs define specialty drugs and review strategies on management of specialty drug costs, such as formularies, cost sharing, step therapy, and prior authorization.

CMS Advisory Opinion 2017-01 Approves Pop-up Alerts to Physicians Through Online Laboratory Portal

Michaela D. Poizner, 615.726.5695mpoizner@bakerdonelson.com

A clinical laboratory has received a green light from CMS to offer pop-up notifications alerting physicians of various potential issues (Laboratory Alerts) through its web-based portal for ordering and reporting results of diagnostic tests. CMS reviewed the proposal to offer the Laboratory Alerts in Advisory Opinion 2017-01, issued in September 2017, and determined that the Laboratory Alerts do not constitute remuneration (42 C.F.R. § 411.351) creating a compensation arrangement that implicates the physician self-referral law (the Stark Law).

CMS Clarifies Streamlined Submission to Self-Referral Disclosure Protocol for Physician Organizations

Kristin Cilento Carter, 410.862.1109kcarter@bakerdonelson.com

In an apparent effort to reduce redundancy, CMS issued an FAQ clarifying a simplified process for submissions to the CMS Voluntary Self-Referral Disclosure Protocol (SRDP) involving financial relationships with physicians who are deemed to “stand in the shoes” of their physician organization.

Under the revised SRDP process that became effective as of June 1, 2017, CMS requires SRDP participants to utilize very specific forms to provide detailed information regarding the self-disclosure, including the SRDP Disclosure Form identifying information regarding the disclosing party; the Physician Information Form identifying information regarding each physician included in the disclosure; and the Financial Analysis Worksheet identifying the potential overpayment based on a six-year look back period. Notably, the SRDP forms instruct that for each physician included in the disclosure, a disclosing entity must submit a separate Physician Information Form providing the details of the financial relationship(s) between the physician(s) and disclosing entity. Given this instruction, in circumstances where the disclosed financial arrangement involved a large physician-owned organization, a disclosing entity seemingly would have been required to submit multiple redundant Physician Information Forms for each physician owner who is deemed to “stand in the shoes” of the organization pursuant to 42 C.F.R. § 411.354(c).

CMS Requests Industry Feedback on “New Direction” for the Innovation Center

Matthew W. Horton, 410.862.1182mhorton@bakerdonelson.com

CMS is seeking comments through a Request for Information (RFI) on a “new direction” for the CMS Innovation Center. The RFI includes focus areas identified by CMS, but the RFI welcomes all stakeholder input on “additional ideas and concepts,” including the “future direction of the Innovation Center.” This is an opportunity for stakeholders to provide feedback or suggest new ideas that could shape the Innovation Center’s policies and priorities on future payment models. The deadline to submit comments to the RFI is November 20, 2017.

Texas Medical Board Proposes New Rules on Heels of Relaxed Telemedicine Laws

Emily H. Wein, 410.862.1160ewein@bakerdonelson.com

The Texas Medical Board recently proposed changes to its telemedicine regulations (22 Tex. Admin. Code §§ 174.1 – 174.12) to follow the amendments to Section 111 of the Texas Occupations Code governing the practice of telemedicine and telehealth. (See 2017 Texas Senate Bill 1107.) The statutory amendments, among other things, removed the in-person exam requirement for purposes of establishing a valid practitioner-patient relationship and added a provision allowing the establishment of such relationship through “telemedicine medical services.” The revised law also tasks the state regulatory boards for medicine, nursing, physician assistants and pharmacy with the joint promulgation of rules relative to valid prescriptions, with the mandate that such rules allow for the establishment of a practitioner-patient relationship via telemedicine.

HBMA Washington Report – September Issue

Washington Report – September, 2017
(Covers activity between 9/1/17 and 9/30/17)
Bill Finerfrock, Matt Reiter, Nathan Baugh,
Deanna Marcarelli, Carolyn Bounds

Washington Report – September Issue

  • Latest Republican ACA Repeal/Replace Effort Fails
  • What Would Graham-Cassidy Do?
  • Medicare Unveils Design for New Beneficiary Cards
  • HHS Secretary Tom Price Resigns Over Travel Expense Scrutiny
  • Administration Withdraws Health Plan Administrative Simplification Compliance Rule
  • CMS Rescinds Confusing Date of Service MLN Matters Article
  • CMS Seeking to Redefine Role of Innovation Center
  • With ACA Repeal/Replace on Hold, Congress Takes Up Other Health Policy Measures
  • Republicans Unveil Tax Reform Framework
  • CMS Develops Qualified APM Participant Look-Up Tool
  • GAO Conducts Analysis of CMS Fraud Prevention System
  • CMS Transmittals