Today, the Office of Inspector General published in the Federal Register an lengthy proposed rule that modifies the current Civil Monetary Penalty Rules. While no direct mention is made about Section 111 Medicare & Medicaid SCHIP Extension Act of 2007 penalties, it is important to understand that these new rules will have a bearing on how those penalties are ultimately assessed. MMSEA penalties are assessed/prosecuted based on the Civil Monetary Penalty Rules under the MSP law. Therefore, it is important to understand how these changes will potentially impact that issue.
Over the next week we will analyze the proposed rule as we prepare comments that are due to OIG on 7/11/2014. We encourage our readers to also submit comments as well so the Agency has the best possible information before the proposed rule is finalized.
We at Franco Signor will monitor the development of this rule and assess how it may impact the implementation of your MSP compliance program. There is no question that OIG is an important Agency to monitor, in addition to CMS when improving your compliance program. Call us today to discuss how our products and services, including our SMART Comply™ technology, can provide total MSP compliance visibility.