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Establishing and implementing necessary structure and procedures
Medicare Compliance Officer advice and consultation
Coordination and cooperation with in-house counsel
Ongoing consultation on a retainer basis
Updating policies, procedures, and forms to meet changing regulatory requirements
Liaison and routine dealings with CMS
Medicare Compliance and Quality Improvement Committee
Performance oversight and Reporting-Legal Issues
Fraud, Waste, and Abuse Policies and Procedures and Control Programs
CMS Monitoring and Reporting Issues
State/Federal Regulatory Issues
Liaison and routine dealings with CMS
The firm highly recommends that a Provider designate one person to interface with CMS on all matters, from the very routine to the most threatening, and that this person should be the Medicare Compliance Officer (MCO). This provides uniformity of communications, and places the responsibility for timely and correct responses upon the shoulders of the person designated as the primary officer responsible for Medicare Compliance. Of course, the MCO will normally then delegate responsibility to the appropriate department to gather the necessary data, draft a report, and then forward to the MCO for final response.
If an insurer has experienced personnel in key liaison positions for those persons who will normally receive and respond to routine inquiries and questions from the CMS regulators, in many instances legal counsel will not be necessary, and the personnel, usually not licensed attorneys, will be able to respond to the inquiries. Furthermore, if an inquiry from CMS begins at a fairly routine level, and is confronted with the appearance of outside counsel at an otherwise low key meeting, alarm bells may ring, and the presence of counsel may actually be self-defeating and cause further inquiry.
The CMS Compliance Counsel Department of Lippe & Associates offers ongoing consultation with its clients who engage the firm for such routine matters. If the firm is engaged to review the insurer's program from an operational viewpoint, and is on retainer to provide such consultation, we will consult with the authorized personnel designated as appropriate contacts to advise them on the responses to the "routine" inquiries. Given the requisite basic familiarity with the client's operations and framework, we will provide such consultation to assist in responding on time-critical matters.