Helpful Tips to Speed Up the Medicare Prepayment Review Process

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

For Medicare providers, being notified of an impending audit is not welcome news. Being notified of a prepayment review is even worse. In a prepayment review, the health care provider must submit documentation to the Centers for Medicare & Medicaid Services (CMS) contractor before ever receiving payment. The health care provider will only receive payment (typically months later) if the contractor is satisfied with the provider’s documentation. This can be financially disastrous for the health care provider, who still must pay day-to-day expenses while waiting for a decision.

CMS Contractors.

If you have received notice of prepayment review, you first need to determine the contractor that has initiated the review. CMS contracts with four types of contractors:

– Medicare Administrative Contractors (MACs);
– Comprehensive Error Rate Testing (CERT) contractors;
– Recovery Audit Contractors (RACs); and
– Zone Program Integrity Contractors (ZPICs).

Both the Medicare Administrative Contractors (MACs) and Zone Program Integrity Contractors (ZPICs) can initiate prepayment reviews.

MAC Prepayment Reviews.

MACs will initiate prepayment reviews of health care providers suspected of improper billing for services. If the MAC detects anything resembling fraud during the process, the prepayment review can extend for up to a year or more. However, MACs will generally terminate the prepayment review when the health care provider demonstrates a pattern of correct billing. Health care providers who are notified of a MAC prepayment review should consult with an experienced health care attorney from the beginning of the process. An experienced health attorney will be able to assist the health care provider to ensure everything is in place for a speedy prepayment review.

ZPIC Prepayment Reviews.

A MAC may refer a health care provider to a ZPIC for a benefit integrity prepayment review if they suspect fraud. A ZPIC can also initiate a benefit integrity prepayment review based on data analysis.  Unlike MACs, ZPICs generally are less willing to communicate with health care providers about the prepayment review.

Additionally, there are different time limitations for a benefit integrity prepayment review. The MAC prepayment review is governed by Medicare Manual provisions that stipulate a maximum length of time on a prepayment review. However, a benefit integrity prepayment review can last indefinitely, if the basis for the review is not timely and properly addressed by the health care provider.

Further, ZPICs make fraud referrals to the Department of Health and Human Services (HHS) Office of the Inspector General (OIG). Thus, health care providers should view ZPIC correspondence as the start of a potentially larger investigation. An experienced health care attorney should be contacted immediately after a health care provider receives any contact from ZPIC.

How to Accomplish a Speedy Review.

In many cases, the health care provider will be on Medicare prepayment review until its billing accuracy reaches a certain percentage. However there are other steps to help speed up the Medicare prepayment audit process.

1.  Read all Correspondence from the Contractor Carefully.

Pay close attention to all correspondence sent by the contractor. Make a note of the due date given and make sure your response is sent well within the time limits. Denials will usually occur if a response is not received by the given deadline. Also be sure that you send your response to the correct office.

2.  Be Familiar with Local Coverage Determinations (LCDs).

You should read and be familiar with any and all applicable local coverage determinations (LCDs) and national coverage determinations (NCDs) for any codes, services, supplies or equipment you are billing.

3.  Contact an Experienced Health Care Attorney Immediately.

A health care attorney who is experienced in prepayment reviews will be able to help you file a proper response in a timely fashion. An attorney will also be able to help find out additional information on why you have been placed on prepayment review and exactly what documentation the auditor is looking for. Alternatively, a health care consultant who has actual experience in working on Medicare cases and who has been an expert witness in Medicare hearings may be able to assist, as well.

4.  Contact the Contractor Responsible for the Review.

After you have consulted with an attorney, schedule a call with the contractor responsible for your prepayment review. During the call learn as many details about the audit as you can and find out what the reviewer wants in the documentation.

However, do not:
a. Argue with the auditor.
b. Berate or demean the auditor.
c. Challenge the auditor’s knowledge, competence or credentials.
d. Ask the auditor to prove anything to you.
e. Demand to speak to the auditor’s supervisor.

5.  Do Not File Duplicate Claims.

Keep track of all requests for additional documentation and when they were received. Do not think that you need to file another claim for the same items just because you have not received a response as quickly as other claims where additional documentation was not requested. If you provide duplicate claims, the contractor’s decision can be delayed.

6.  Organize all Submissions and Results.

You must keep track of the date you receive the document request for a claim, the date you submitted the documentation for review, the result of the audit and the date the result was received. This will help you realize how quickly claims are reviewed. If a one claim’s review has taken longer than the others you’ve submitted, you can contact the reviewer to make sure they have received the claim and everything is in order.

7.  Follow-up with the Contractor for Feedback.

Keep in contact with the contractor throughout the review. This will help to maintain the relationship you initiated after first receiving notice of the prepayment review. This will also help you keep track of any issues and resolve them. Be sure to discuss how you can improve your claim submissions to meet the standards of your particular reviewer.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent health care providers in prepayment reviews. They also represent physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Sources:

Baird, Jeff. “Q&A with Jeff Baird: How to Prepare for and Survive Prepayment Reviews.” Home Care. (Sept. 13, 2010). From http://homecaremag.com/news/prepayment-review-faq-20100913/

Greene, Stephanie Morgan. “5 Steps to Get Off Pre-Payment Audit – Quickly!” Harrington Managment Group. (Mar. 18, 2011). From
http://homecaremag.com/news/prepayment-review-faq-20100913/

About the Author:  George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

Tag Words: prepayment audit, prepayment review, Medicare audits, Medicare, Centers for Medicare & Medicaid Services, CMS, RAC, Recovery Audit Contractor, ZPIC, Zone Program Integrity Contractor, MAC, Medicare Administrative Contractor, CERT contractor, Comprehensive Error Rate Testing contractor, overpayment, prepayment reviews, First Coast Service Options, Medicare contractor, Medicare fraud, Medicare investigation, Medicare overbilling, OIG

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 2018 The Health Law Firm. All rights reserved.

Adventist Health System Settles Whistleblower Lawsuit

8 Indest-2008-5By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On December 18, 2013, Adventist Health System/Sunbelt Inc., the parent company of Orlando-based Florida Hospital, settled a whistleblower lawsuit, according to court documents. The whistleblower lawsuit, filed in 2010, stated that seven Adventist hospitals in Florida overbilled the federal government between 1995 and 2009, allegedly resulting in tens of millions of dollars in false claims, according to an article in the Orlando Sentinel and other sources.

Click here to read the Order of Dismissal.

Previous reports from the Orlando Sentinel stated that the lawsuit could have damages of more than $100 million, but the details of the settlement are not yet available.

Alleged Details in the Case Against Adventist Health System.

The lawsuit claims that seven Adventist hospitals in Florida allegedly used improper coding to overbill Medicare, Medicaid and Tricare. In addition, the lawsuit alleges the hospitals also overbilled for a drug used in MRI scans and billed for computer analyses that were never performed.

The plaintiffs are a bill-coding and compliance officer, and a radiologist that were either employed or affiliated with Florida Hospital Orlando between 1995 and 2009. They allege the discrepancies occurred during those years.

To read the entire False Claims Act complaint filed, click here.

Hospitals that allegedly partook in the overbilling include: Florida Hospital Orlando, Florida Hospital Altamonte, Florida Hospital East Orlando, Florida Hospital Apopka, Florida Hospital Celebration Health, Florida Hospital Kissimmee and Winter Park Memorial Hospital.

This case was scheduled to go to trial in December 2013.

Click here to read more on this case from my previous blog.

Most Qui Tam Claims Filed by Employees.

From our review of qui tam cases that have been unsealed by the government, it appears most of these are filed by physicians, nurses or hospital staff employees who have some knowledge of false billing or inappropriate coding taking place. Normally the government will want to see some actual documentation of the claims submitted by the hospital or other institution. Usually physicians, nurses or staff employees have access to such documentation. Whistleblowers are urged to come forward as soon as possible. In many circumstances, documentation that shows the fraud “disappears” or cannot be located once it is known that a company is under investigation.

To learn more on whistleblower/qui tam cases, read our two-part blog. Click here for part one, and click here for part two.

Contact Health Law Attorneys Experienced with Qui Tam or Whistleblower Cases.

Attorneys with The Health Law Firm also represent health care professionals and health facilities in qui tam or whistleblower cases both in defending such claims and in bringing such claims. We have developed relationships with recognized experts in health care accounting, health care financing, utilization review, medical review, filling, coding, and other services that assist us in such matters. We have represented doctors, nurses and others as relators in bringing qui tam or whistleblower cases, as well.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Comments?

Individuals working in the health care industry often become aware of questionable activities. Often they are even asked to participate in it. In many cases the activity may amount to fraud on the government. Has this ever happened to you? Please leave any thoughtful comments below.

Sources:

Aboraya, Abraham. “Adventist Health Whistleblower Lawsuit Settled.” Orlando Business Journal. (December 19, 2013). From: http://www.bizjournals.com/orlando/blog/2013/12/adventist-health-whistleblower-lawsuit.html

United States of America and State of Florida ex rel., Amanda Dittman and charlotte Elenberger, M.D. vs Adventist Health System/Sunbelt, Inc. Case No. 6:10-cv-1062-Orl-28GJK. Order of Dismissal. (December 18, 2013). From: http://assets.bizjournals.com/orlando/pdf/document.pdf

Jameson, Marni. “Whistleblower Lawsuit Alleges Florida Hospital Filed Millions in False Claims.” Orlando Sentinel. (August 8, 2012). From: http://articles.orlandosentinel.com/2012-08-08/health/os-whistleblower-lawsuit-florida-hospital-20120808_1_adventist-health-suit-claims-whistleblower-lawsuit

Amanda Dittman and Charlotte Elenberger, M.D. v. Adventist Health Systems/Sunbelt, Inc. No. 6:10-cv-01062-JA-GJK. False Claims Act Complaint. (July 15, 2010). From: http://www.thehealthlawfirm.com/uploads/whistleblower-lawsuit-adventist.pdf

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

 

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Kansas Cancer Treatment Center and Owner Pay $2.9 Million Settlement for Alleged False Claims Act Violations

IndestBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

A whistleblower or qui tam lawsuit against a cancer treatment facility in Kansas has been settled. On April 14, 2014, the Hope Cancer Institute and its owner agreed to pay $2.9 million to resolve allegations that they violated the False Claims Act by defrauding Medicare, Medicaid and the Federal Employee Health Benefits Program. According to the complaint, it is alleged that the cancer treatment facility submitted false claims for drugs and services that were not provided to beneficiaries.

Click here to read the entire whistleblower complaint filed in 2012.

The complaint identifies three former employees of Hope Cancer Institute as the plaintiffs or “relators” in this case.

Owner Allegedly Instructed Employees to Submit Inflated Claims and Altered Medical Records.

According to the Department of Justice (DOJ), between 2007 and 2011, the Hope Cancer Institute’s owner allegedly instructed employees to bill for a predetermined amount of cancer drugs at certain dosage levels. However patients were allegedly given lower dosages of these drugs. This resulted in the center submitting false claims to federal health care programs for drugs that were not actually provided to beneficiaries. The three plaintiffs also stated they watched the owner use a paper cutter and tape to alter medical records before faxing them to Medicare. The employees’ investigation allegedly turned up altered documents for 13 patients.

To read the entire press release from the DOJ, click here.

The claims made against the Hope Cancer Institute and its owner are allegations. There has been no determination of liability.

Most Qui Tam Claims Filed by Employees.

The plaintiffs in this case filed the lawsuit against their employer under the qui tam or whistleblower provision of the False Claims Act. This law encourages whistleblowers to file fraud claims on behalf of the government by giving them a share of whatever the government collects, usually 15 percent (15%) to twenty-five percent (25%). Under the law, the employees are also required to give the DOJ the evidence they have collected so the government can join the lawsuit.

From our review of qui tam cases that have been unsealed by the government, it appears most of these are filed by physicians, nurses or staff employees who have some knowledge of false billing or inappropriate coding taking place. Typically the government will want to see some actual documentation of the claims submitted by the hospital or other institution. Physicians, nurses or staff employees usually have access to such documentation. Whistleblowers are urged to come forward as soon as possible. In many circumstances, documentation showing fraud “disappears” or cannot be located once it is known that a company is under investigation.

To learn more on whistleblower cases, read our two-part blog. Click here for part one, and click here for part two.

Contact Health Law Attorneys Experienced with Qui Tam or Whistleblower Cases.

Attorneys with The Health Law Firm also represent health care professionals and health facilities in qui tam or whistleblower cases both in defending such claims and in bringing such claims. We have developed relationships with recognized experts in health care accounting, health care financing, utilization review, medical review, filling, coding, and other services that assist us in such matters. We have represented doctors, nurses and others as relators in bringing qui tam or whistleblower cases, as well.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Comments?

Individuals working in the health care industry often become aware of questionable activities. Often they are even asked to participate in it. In many cases the activity may amount to fraud on the government. Has this ever happened to you? Please leave any thoughtful comments below.

Sources:

Department of Justice. “Government Settles False Claims Act Allegations Against Kansas Cancer Treatment Facility and Its Owner.” Department of Justice. (April 14, 2014). From: http://www.justice.gov/opa/pr/2014/April/14-civ-378.html

United States of America ex rel., Krisha Turner, Crystal Dercher and Amanda Reynolds v. Hope Cancer Institute, Inc. Case Number 2:12-cv-02122-EFM-JPO. Complaint. (March 1, 2012).

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2014 The Health Law Firm. All rights reserved.

“Doctor of Death” Trial Could Ignite Stricter Oversight in the Healthcare Industry

8 Indest-2008-5By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On paper, one Detroit-area oncologist appeared to be a wildly successful professional with impeccable medical credentials. According to his medical practice’s website, he went to medical school at Cornell Medical College, did an internal medicine residency at Maimonides Medical Center in Brooklyn, New York, and then completed a medical oncology fellowship at Memorial Sloan-Kettering Cancer Center, a very well-respected facility. The oncologist ran a professional practice of seven locations with a total of 60 employees.

However, on September 24, 2014, his reputation and accolades faded when he pleaded guilty to intentionally and wrongfully diagnosing healthy patients with cancer. He also admitted to giving these patients chemotherapy solely for the purpose of making a profit.

For healthcare professionals, this act is an obvious violation of the oath they took to serve their patients and to do no harm. But, if this oncologist is found guilty, you can be assured that oncologists, physicians, dentists, and all other healthcare professionals will be under a microscope to help ensure that something this egregious and dishonest does not happen again.

Allegations Against the Oncologist.

The details of the allegations, obtained from various employee whistleblowers, range from the mundane to the horrific. In the Federal Bureau of Investigation’s (FBI) complaint against the oncologist, there are dozens of examples of his wrongdoing described. The activities of which the doctor is accused include:

– Administration of unnecessary chemotherapy to patients in remission;
– Deliberate misdiagnosis of patients as having cancer to justify unnecessary cancer treatment;
– Administration of chemotherapy to end-of-life patients who would not benefit from the treatment;
– Deliberate misdiagnosis of patients without cancer to justify expensive testing;
– Fabrication of other diagnoses such as anemia and fatigue to justify unnecessary hematology treatments; and
– Distribution of controlled substances to patients without medical necessity.

There is also an issue of Medicare fraud. For the past six years, the doctor is accused of seeing a large number of patients per day. He would then bill every patient at the highest possible billing code, even though he allegedly only spent a few minutes with each patient. The amount of money related to the doctor’s Medicare fraud scheme is a staggering $35 million.

Click here to read the FBI’s complaint against the oncologist.

Charges.

The oncologist is facing a an abundance of legal issues. In all, the oncologist pleaded guilty in U.S. District Court to 13 counts of healthcare fraud, one count of conspiracy to pay or receive kickbacks and two counts of money laundering. He will be sentenced in February 2015 and faces up to 175 years in prison.

Other Healthcare Providers Could Pay for Oncologist’s Greed.

If the oncologist is found guilty, the aftereffects will surely be felt throughout the industry. For example, healthcare providers will need to more closely watch their Medicare billing. Any reimbursement submitted to Medicare will be under tight scrutiny. Keep in mind that Medicare pays close attention to the percentage of patients billed at each level. If a physician bills for every patient at the highest level, it’s going to send up a huge red flag. If you or your practice is being audited, click here for some tips on responding to a Medicare audit.

On top of the extensive healthcare fraud charges, the oncologist allegedly misled, endangered, and injured his patients. He betrayed the trust and privilege given to him as a physician by society, all in the name of greed. According to an article in The Washington Post, more than one patient died under the care of the oncologist. These families are now left to figure out whether their loved ones actually had cancer and died of chemotherapy complications, or whether they died of an actual cancerous ailment.

It’s crucial to remember that cutting corners to make a profit as a healthcare professional leads to great ramifications. Once a healthcare professional’s license and reputation are questioned, it is not an industry one can easily get back into.

Comments?

In your opinion, what is the worst offense this oncologist allegedly committed? Explain. Please leave any thoughtful comments below.

Contact Health Law Attorneys Experienced with Investigations of Health Professionals and Providers.

The attorneys of The Health Law Firm provide legal representation to physicians, nurses, nurse practitioners, CRNAs, dentists, pharmacists, psychologists and other health providers in accusations of disruptive behavior, Department of Health (DOH) investigations, Drug Enforcement Administration (DEA) investigations, FBI investigations, Medicare investigations, Medicaid investigations and other types of investigations of health professionals and providers.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Sullivan, Gail. “‘Death Doctor’ Who Profited from Unnecessary Chemotherapy for Fake Cancers Could Resume Practice in 5 Years.” The Washington Post. (October 1, 2014). From: http://www.washingtonpost.com/news/morning-mix/wp/2014/10/01/death-doctor-who-profited-from-unnecessary-chemotherapy-for-fake-cancers-could-resume-practice-in-three-years/

“Prominent Michigan Cancer Doctor Pleads Guilty: ‘I Knew That It Was Medically Unnecessary’.” The Inquisitr. (September 24, 2014). From: http://www.inquisitr.com/1485160/prominent-michigan-cancer-doctor-pleads-guilty-i-knew-that-it-was-medically-unnecessary/

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2014 The Health Law Firm. All rights reserved.

Whistleblower Lawsuit Alleges Florida Adventist Hospitals Overbilled Millions of Dollars

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

A whistleblower lawsuit based on information from a former Florida Hospital Orlando billing employee and a former staff physician alleges that seven of Adventist’s Florida hospitals overbilled the federal government between 1995 and 2009, resulting in tens of millions of dollars in false or padded medical claims, according to an article in the Orlando Sentinel and other sources.

To read the entire False Claims Act complaint filed, click here.

Hospital Allegedly Used Improper Coding to Overbill Medicare, Medicaid and Tricare.

The suit claims that seven Adventist Florida hospitals allegedly used improper coding to overbill Medicare, Medicaid and Tricare. In addition, the lawsuit alleges the hospitals also overbilled for a drug used in MRI scans and billed for computer analyses that were never performed.

The article states that the plaintiffs are a bill-coding and compliance officer, and a radiologist that were either employed or affiliated with Florida Hospital Orlando between 1995 and 2009. They allege the discrepancies occurred during those years. The lawsuit was filed in July 2010, according to the Orlando Sentinel.

Hospitals that allegedly partook in the overbilling include: Florida Hospital Orlando, Florida Hospital Altamonte, Florida Hospital East Orlando, Florida Hospital Apopka, Florida Hospital Celebration Health, Florida Hospital Kissimmee and Winter Park Memorial Hospital.

The U. S. district court judge has set the trial in this case for December 2013.

Click here to read the Orlando Sentinel article.

Steep Fines if Found Liable. 

If the health system is found liable for the false claims it would be responsible for repaying the excess money received, for paying civil penalties of $5,500 to $11,000 per false claim, and damages.

Under the False Claims Act, Whistleblowers Encouraged to Speak Up.

Whistleblowers stand to gain substantial amounts, sometimes as much as thirty percent (30%), of the award under the False Claims Act (31 U.S.C. Sect. 3730). Such awards, often reaching into millions of dollars, encourage employees to come forward and report fraud.

You can learn more on the False Claims Act on the Department of Justice (DOJ) website.

Contact Health Law Attorneys Experienced with Medicaid and Medicare Qui Tam or Whistleblower Cases.

In addition to our other experience in Medicare, Medicaid and Tricare cases, attorneys with The Health Law Firm also represent health care professionals and health facilities in qui tam or whistleblowers cases. We have developed relationships with recognized experts in health care accounting, health care financing, utilization review, medical review, filling, coding, and other services that assist us in such matters.

To learn more on our experience with Medicaid and Medicare quit tam or whistleblower cases, visit our website.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Jameson, Marni. “Whistleblower Lawsuit Alleges Florida Hospital Filled Millions in False Claims.” Orlando Sentinel. (August 8, 2012). From: http://articles.orlandosentinel.com/2012-08-08/health/os-whistleblower-lawsuit-florida-hospital-20120808_1_adventist-health-suit-claims-celebration-health/2

Gamble, Molly. “Whistleblower Suit Alleges Florida Adventist Hospitals Overbilled Tens of Millions.” Becker’s Hospitals Review. (August 9, 2012). From: http://www.beckershospitalreview.com/legal-regulatory-issues/whistleblower-suit-alleges-florida-adventist-hospitals-overbilled-tens-of-millions.html

Flagler Live and Kaiser Health News. “Florida Hospital Flagler Spared Sister Hospitals’ Fraud Lawsuit and Medicare Penalties.” Flagler Live. (August 13, 2012). From: http://flaglerlive.com/42723/adventist-lawsuit-medicare/

Amanda Dittman and Charlotte Elenberger, M.D. v. Adventist Health Systems/Sunbelt, Inc. No. 6:10-cv-01062-JA-GJK (July 15, 2010), available at: http://flaglerlive.com/wp-content/uploads/whistleblower-lawsuit-adventist.pdf

Justice.Gov. “The False Claims Act.” Department of Justice. From: http://www.justice.gov/civil/docs_forms/C-FRAUDS_FCA_Primer.pdf

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.Copyright © 1996-2012 The Health Law Firm. All rights reserved.

How to Speed Up the Medicare Prepayment Review Process

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

For Medicare providers, being notified of an impending audit is not welcome news. Being notified of a prepayment review is even worse. In a prepayment review, the health care provider must submit documentation to the Centers for Medicare & Medicaid Services (CMS) contractor before ever receiving payment. The health care provider will only receive payment (typically months later) if the contractor is satisfied with the provider’s documentation. This can be financially disastrous for the health care provider, who still must pay day-to-day expenses while waiting for a decision.

CMS Contractors.

If you have received notice of prepayment review, you first need to determine the contractor that has initiated the review. CMS contracts with four types of contractors:

– Medicare Administrative Contractors (MACs);

– Comprehensive Error Rate Testing (CERT) contractors; 

– Recovery Audit Contractors (RACs); and

– Zone Program Integrity Contractors (ZPICs).

Both the Medicare Administrative Contractors (MACs) and Zone Program Integrity Contractors (ZPICs) can initiate prepayment reviews.

MAC Prepayment Reviews.

MACs will initiate prepayment reviews of health care providers suspected of improper billing for services. If the MAC detects anything resembling fraud during the process, the prepayment review can extend for up to a year or more. However, MACs will generally terminate the prepayment review when the health care provider demonstrates a pattern of correct billing. Health care providers who are notified of a MAC prepayment review should consult with an experienced health care attorney from the beginning of the process. An experienced health attorney will be able to assist the health care provider to ensure everything is in place for a speedy prepayment review.

ZPIC Prepayment Reviews.

A MAC may refer a health care provider to a ZPIC for a benefit integrity prepayment review if they suspect fraud. A ZPIC can also initiate a benefit integrity prepayment review based on data analysis.  Unlike MACs, ZPICs generally are less willing to communicate with health care providers about the prepayment review.

Additionally, there are different time limitations for a benefit integrity prepayment review. The MAC prepayment review is governed by Medicare Manual provisions that stipulate a maximum length of time on a prepayment review. However, a benefit integrity prepayment review can last indefinitely, if the basis for the review is not timely and properly addressed by the health care provider.

Further, ZPICs make fraud referrals to the Department of Health and Human Services (HHS) Office of the Inspector General (OIG). Thus, health care providers should view ZPIC correspondence as the start of a potentially larger investigation. An experienced health care attorney should be contacted immediately after a health care provider receives any contact from ZPIC.

How to Accomplish a Quick Review.

In many cases, the health care provider will be on Medicare prepayment review until its billing accuracy reaches a certain percentage. However there are other steps to help speed up the Medicare prepayment audit process.

1.  Read everything from the Contractor Carefully.

Pay close attention to all correspondence sent by the contractor. Make a note of the due date given and make sure your response is sent well within the time limits. Denials will usually occur if a response is not received by the given deadline. Also be sure that you send your response to the correct office.

2.  Read and Be Familiar with all Local Coverage Determinations (LCDs).

You should read and be familiar with any and all applicable local coverage determinations (LCDs) and national coverage determinations (NCDs) for any codes, services, supplies or equipment you are billing.

3.  Contact an Experienced Health Care Attorney Immediately.

A health care attorney who is experienced in prepayment reviews will be able to help you file a proper response in a timely fashion. An attorney will also be able to help find out additional information on why you have been placed on prepayment review and exactly what documentation the auditor is looking for. Alternatively, a health care consultant who has actual experience in working on Medicare cases and who has been an expert witness in Medicare hearings may be able to assist, as well.

4.  Contact the Contractor Responsible for the Review.

After you have consulted with an attorney, schedule a call with the contractor responsible for your prepayment review. During the call learn as many details about the audit as you can and find out what the reviewer wants in the documentation.

However, DO NOT:

  a. Argue with the auditor.

  b. Berate or demean the auditor.

  c. Challenge the auditor’s knowledge, competence or credentials.

  d. Ask the auditor to prove anything to you.

  e. Demand to speak to the auditor’s supervisor.

5.  Do Not File Duplicate Claims.

Keep track of all requests for additional documentation and when they were received. Do not think that you need to file another claim for the same items just because you have not received a response as quickly as other claims where additional documentation was not requested. If you provide duplicate claims, the contractor’s decision can be delayed.

6.  Keep all Submissions and Results Organized.

You must keep track of the date you receive the document request for a claim, the date you submitted the documentation for review, the result of the audit and the date the result was received. This will help you realize how quickly claims are reviewed. If a one claim’s review has taken longer than the others you’ve submitted, you can contact the reviewer to make sure they have received the claim and everything is in order.

7.  Follow-up with the Contractor for Feedback.

Keep in contact with the contractor throughout the review. This will help to maintain the relationship you initiated after first receiving notice of the prepayment review. This will also help you keep track of any issues and resolve them. Be sure to discuss how you can improve your claim submissions to meet the standards of your particular reviewer.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent health care providers in prepayment reviews. They also represent physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Sources:

Baird, Jeff. “Q&A with Jeff Baird: How to Prepare for and Survive Prepayment Reviews.” Home Care. (Sept. 13, 2010). From http://homecaremag.com/news/prepayment-review-faq-20100913/

Greene, Stephanie Morgan. “5 Steps to Get Off Pre-Payment Audit – Quickly!” Harrington Managment Group. (Mar. 18, 2011). From http://homecaremag.com/news/prepayment-review-faq-20100913/

About the Author:  George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.

Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Office of Inspector General (OIG) Scrutinizes Billing at South Florida Mental Health Clinics

By Lance O. Leider, J.D., and George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On August 16, 2012, the Office of Inspector General (OIG) released a report on questionable billing by mental health centers. The report focuses on the nation’s mental health clinics that overbilled Medicare in 2010, some by tens of millions of dollars. The majority of these clinics were located in South Florida, Texas and Louisiana.

To see the full report from the OIG, click here.

Two Big Busts in Florida Mental Health Clinics for Medicare Fraud.

According to an article in the Miami Herald: “No area of the country cheats Medicare quite like South Florida.” To see this article from the Miami Herald, click here.

In the report, the OIG specifically named a bust of two Miami-area doctors, one Miami-area therapist and two others for their participation in a Medicare fraud scheme. The case involved the nation’s biggest mental health chain and more than $205 million in fraudulent billing. Executives of the company were sentence in June 2012, to anywhere from 50 years to 91 months.

We previously blogged about this news story. Click here to read that blog. To see a copy of the press release on this case from the Department of Justice (DOJ), click here.

The Miami Herald article outlines the case of another South Florida mental-health clinic. The clinic’s owner, his son, his daughter and five others were found guilty on August 31, 2012, of conspiring to cheat $57 million from the federal program for the elderly and disabled. The owner, his son, an operating officer and another manager were also convicted of conspiracy to commit health care fraud by collecting $11 million in Medicare payments for therapy services that were not needed or provided from 2007 to 2011.

Click here to see the full press release on this case from the DOJ.

OIG Scrutinizes Medicare for Lack of Regulations.

In the report, the Inspector General (IG) said these two instances of Medicare fraud are examples of the federal program’s “vulnerabilities.” The report scrutinizes the Medicare program for it’s lack of regulating about 200 mental health centers in 25 states that received an estimated $218.6 million in 2010.

Medicare Officials Admit Mental Health Services are Susceptible  to Fraud and Abuse.

In the Miami Herald article, Medicare officials responded to the OIG by acknowledging that mental health services have been vulnerable to fraud and abuse in the past, but said Medicare is currently taking steps to address these issues. These steps include adopting a computer program that will screen prospective clinic operators; it will perform criminal background checks and closely examine claims which are paid within 14 days.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent health care providers in Medicare audits, ZPIC audits and RAC audits throughout Florida and across the U.S. They also represent physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Sources:

Weaver, Jay. “Feds Spotlight South Florida Mental Health Clinics for Medicare Fraud.” The Miami Herald. (August 28, 2012). From: http://www.miamiherald.com/2012/08/28/2972637/feds-spotlight-south-floridas.html

Levinson, Daniel. “Questionable Billing By Community Mental Health Centers.” Office of Inspector General. (August 2012). From: /uploads/OIG on Medicare fraud in Mental Health Clinics.pdf

Department of Justice. “Eight Individuals and a Corporation Convicted at Trial in Florida in $50 Million Medicare Fraud.” United States Department of Justice. (August 24, 2012). From: http://www.justice.gov/opa/pr/2012/August/12-crm-1048.html.

Valle, Alicia. “Doctors, Therapist and Recruiters from Miami-Area Mental Health Care Corporation Convicted for Participating in $205 Million Medicare Fraud Scheme” U.S. Attorney’s Office for the Southern District of Florida. (June 1, 2012). From: http://www.justice.gov/usao/fls/PressReleases/120601-03.html

About the Authors: Lance O. Leider is an attorney with The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Avenue, Altamonte Springs, Florida 32714, Phone:  (407) 331-6620.

George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.

Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Hospice of the Comforter Inc., Faces Whistleblower Lawsuit

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On September 6, 2012, the Department of Justice (DOJ) announced it will join in a whistleblower lawsuit alleging false Medicare billings against Hospice of the Comforter Inc., (HOTCI). The hospice is located in Altamonte Springs, a suburb of the Orlando area, and provides hospice services to local patients.

To read the entire whistleblower complaint filed, click here.

Allegations in the Lawsuit Against HOTCI.

According to the DOJ, the lawsuit was filed by the former vice president of finance for HOTCI. The case alleges HOTCI submitted false claims to Medicare for hospice care patients who were not terminally ill. The lawsuit also claims an executive at the hospice told employees to admit Medicare recipients for hospice care even before there had been a determination that the patients were eligible for the hospice benefit.

Initial Medicare Audit Allegedly Triggered Discharges.

In an Orlando Sentinel article, the plaintiff states that in an initial audit, in 2010, the government found HOTCI had a billings error rate of eighteen percent (18%), which triggered a second review. The plaintiff is accusing HOTCI of then creating an internal committee to review the eligibility of its Medicare patients. The committee discharged at least 150 patients between 2009 and 2010 as being ineligible for the Medicare hospice benefit.

According to the Orlando Sentinel, a representative from HOTCI said the discharges show that the hospice was taking actions to resolve of the situation on its own and only indicates some hospice patients should have been discharged at a previous point in time – not that they shouldn’t have been admitted at all.

To read the entire Orlando Sentinel article, click here.

Details of the Medicare Hospice Benefit.

According to the DOJ, the Medicare hospice benefit is available to patients who choose palliative treatment (medical care focused on providing patients with relief from pain and stress) for a terminal illness, and are expected to live six months or less. When an individual is admitted to a hospice facility, that individual is no longer entitled to receive services designed to cure the illness, or curative care.

Under the False Claims Act, Whistleblowers Can Make a Profit.

Should the government win this case, HOTCI could face up to $33 million in penalties, according to the Orlando Sentinel.

Whistleblowers stand to gain substantial amounts, sometimes as much as thirty percent (30%), of the award under the False Claims Act (31 U.S.C. Sect. 3730). Such awards encourage employees to come forward and report fraud.

You can learn more on the False Claims Act on the DOJ website.

Contact Health Law Attorneys Experienced with Medicaid and Medicare Qui Tam or Whistleblower Cases.

In addition to our other experience in Medicare, Medicaid and Tricare cases, attorneys with The Health Law Firm also represent health care professionals and health facilities in qui tam or whistleblowers cases. We have developed relationships with recognized experts in health care accounting, health care financing, utilization review, medical review, filling, coding, and other services that assist us in such matters.

To learn more on our experience with Medicaid and Medicare quit tam or whistleblower cases, visit our website.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Santich, Kate. “Feds Join Whistleblower Lawsuit Against Hospice of the Comforter” Orlando Sentinel. (August 28, 2012). From: http://articles.orlandosentinel.com/2012-08-28/health/os-whistleblower-lawsuit-hospice-of-the-comforter-20120828_1_hospice-board-members-hospice-care-hospice-founder

Department of Justice. “United States Intervenes in False Claims Act Lawsuit Against Orlando, Florida-area Hospice.” DOJ. (September 6, 2012). From: http://www.justice.gov/opa/pr/2012/September/12-civ-1080.html

U.S. ex rel. Stone v. Hospice of the Comforter, Inc., No. 6:11-cv-1498-ORL-22-AAB (M.D. Fla) United State District Court for the Middle District of Florida Orlando Division. (September 12, 2012), available at http://www.thehealthlawfirm.com/uploads/US%20v%20Hospice%20of%20the%20Comforter.pdf

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Power Wheelchair Suppliers Voice Concerns over New Government Program

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On September 19, 2012, power wheelchair suppliers voiced their concerns over a new government program called the Power Mobility Devices (PMDs) Demonstration at a Senate Special Committee on Aging. Durable Medical Equipment Suppliers (DMES) protested the program because it requires the permission of a Medicare Administrative Contractor (MAC) prior to the delivery of a power wheelchair to the consumer.

To see the Power Mobility Devices (PMDs) Demonstration operational guide from the Centers for Medicare and Medicaid Services (CMS), click here.

Wheelchair Claims Have High Error Rates.

Federal health officials believe these changes are necessary because eighty percent (80%) of the power wheelchair claims that were submitted in 2011 to Medicare did not meet program requirements. That error rate means more than $492 million of improper payments, according to the Associated Press (AP).

The New Program in Detail.

The new program was initiated on September 1, 2012. It now requires all power mobility claims from Medicare patients in California, Florida, Illinois, Michigan, New York, North Carolina and Texas to be submitted for prior authorization. According to a press release by the American Association for Homecare, those seven states receive almost fifty percent (50%) of all the power wheelchairs obtained through Medicare each year.

Click here to see the press release from the American Association for Homecare.

Medicare will only pay for a power wheelchair after a physician and patient meet face-to-face, and the physician prescribes the wheelchair. A DMES is then responsible for recommending the type of wheelchair the patient needs and submitting the claim to Medicare. Under the new program, a doctor or DMES will submit a prior authorization request along with all relevant paperwork supporting the Medicare coverage. The MAC then decides whether the request meets the requirements for coverage.

Under the CMS guidelines, power wheelchairs are only covered by Medicare when patients need them for daily activities and when canes, walkers or manual wheelchairs won’t work for mobility assistance.

Medicare Beneficiaries Get a Sense of False Hope from Television Ads.

According to the AP, a ranking member of the committee suggested the television advertisements for motorized wheelchairs and scooters give consumers the wrong impression about how Medicare coverage can be obtained. He argues these commercials imply Medicare beneficiaries just need to sign a form to receive a power wheelchair. The committee discussed giving authority to regulate the television ads to the CMS.

To listen to testimony from the hearing, click here.

Comments?

What do you think of this story? Leave your comments on this blog below.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare Issues Now.

The attorneys of The Health Law Firm represent durable medical equipment (DME) suppliers and health care providers in Medicare audits, ZPIC audits, MAC audits and RAC audits throughout Florida and across the U.S. They also represent DME suppliers, physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions, termination from the Medicare or Medicaid Program and administrative hearings.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Sources:

Freking, Kevin. “Wheelchair Suppliers Say Crack Down on Medicare Fraud Goes Too Far; Insurer Applauds Effort.” Associated Press. (September 19, 2012). From: http://www.washingtonpost.com/politics/health_care/wheelchair-suppliers-say-effort-to-crack-down-on-medicare-fraud-goes-too-far/2012/09/19/032ee93a-02ab-11e2-9132-f2750cd65f97_story.html

American Association for Homecare. “American Association for Homecare Expects Medicare to Move Past its Deny-at-All-Costs Culture that Routinely Denies Claims for Power Wheelchairs” The Sacramento Bee. (September 20, 2012). From: http://www.sacbee.com/2012/09/19/4835272/american-association-for-homecare.html

Swann, James. “Power Wheelchairs On the Congressional Hot Seat.” Bloomberg BNA. (September 20, 2012). From: http://www.bna.com/power-wheelchairs-congressional-b17179869795/

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.

Copyright © 1996-2012 The Health Law Firm. All rights reserved.

Whistleblower Lawsuit Alleging Medicare Fraud Against Blackstone Medical, Inc., Dismissed

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

A whistleblower lawsuit against Blackstone Medical, Inc., alleging Medicare fraud against Parrish Medical Center, was dismissed by a U.S. District Judge in Tampa, Florida, on August 15, 2012. According to Orthopedics This Week, the case was unsealed on August 8, 2012, but dismissed without prejudice, all pending motions were denied as moot, and the clerk was directed to close the case, just one week after.

To see a copy of the order of dismissal, click here.

Whistleblower Originally Filed False Claims and Kickback Complaint.

According to the lawsuit, the whistleblower was asked to bid on a contract with the Parrish Medical Center in Florida, to provide intraoperative neurophysiological monitoring services. The whistleblower alleges he discovered that a Blackstone Medical, Inc., sales representative and two doctors were using outdated technology that did not allow doctors to actually monitor patients’ neurological activity during procedures.

The plaintiff alleged this discovery uncovered thousands of dollars in Medicare claims being made as part of a kickback scheme, beginning as early as 2002.

To see the original false claims complaint, click here.

Whistleblower Requested Order of Dismissal.

According to an article in Orthopedics This Week, the order of dismissal was in response to the whistleblower’s request for voluntary dismissal without prejudice. This request means that the man keeps his right to come back before the court in the future.

To see the full article from Orthopedics This Week, click here.

Contact Health Law Attorneys Experienced with Medicaid and Medicare Qui Tam or Whistleblower Cases.

In addition to our other experience in Medicare, Medicaid and Tricare cases, attorneys with The Health Law Firm also represent health care professionals and health facilities in qui tam or whistleblowers cases. We have developed relationships with recognized experts in health care accounting, health care financing, utilization review, medical review, filling, coding, and other services that assist us in such matters.

To learn more on our experience with Medicaid and Medicare quit tam or whistleblower cases, visit our website.

To contact The Health Law Firm, please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Eisner, Walter. “Blackstone Florida Whistleblower Lawsuit Dismissed.” Orthopedics This Week. (August 22, 2012). From: http://ryortho.com/companyNews.php?news=2168_Blackstone-Florida-Whistleblower-Lawsuit-Dismissed

Jon Schiff v. Blackstone Medical, Inc., Case Number 8:11-cv-02430-JSM-TBM United States District Court for the Middle District of Florida Tampa Division (October 26, 2011), available at, http://www.thehealthlawfirm.com/uploads/Blackstone%20case.pdf.

Jon Schiff v. Blackstone Medical, Inc., et al., Case No: 8:11-cv-2430-T-30TBM United States District Court Middle District of Florida Tampa Division (August 15, 2012), available at, http://www.thehealthlawfirm.com/uploads/Blackstone%20dismissal.pdf.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law.  He is the President and Managing Partner of The Health Law Firm, which has a national practice.  Its main office is in the Orlando, Florida, area.  www.TheHealthLawFirm.com  The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone:  (407) 331-6620.

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.

Copyright © 1996-2012 The Health Law Firm. All rights reserved.

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