When voluntary disclosure for overpayments is an option rather than an obligation, the provider may encounter diverse opinions among its decision-makers. Some may express a desire to bring the potential problem to the attention of the government and attempt to resolve the matter quickly without incurring criminal penalties, civil fines, or exclusions.
The application of attorney-client privilege is somewhat more complicated in situations where the client is a corporation. Although corporations are entitled to the same protection of confidentiality as noncorporate clients, the application of the privilege often turns on which corporate officials and employees sufficiently personify the corporation as a client.
CPT reporting for surgical heart procedures requires an in-depth understanding of cardiovascular anatomy and terminology. This article reviews CPT reporting for procedures involving cardiac pacemakers and implantable cardioverter-defibrillators based on key details in provider documentation.
In many companies, the compliance officer is the first to become aware of a potential compliance problem that could lead to civil or criminal liability. A best practice is to give the compliance officer the authority to conduct internal investigations.
