In the movie High Plains Drifter, the citizens of the town of Lago saw their Sheriff murdered and their town rendered lawless. The good folks kept their head down and the bad guy vacuumed up everything of value.
That’s what’s going on now in the world of Medicare Advantage.
The Sheriff is dead and there’s no new lawman in sight.
Readers of my newsletter have already had a first glimpse of this blog post.
They know that a Federal court has invalidated CMS’ “2014 Overpayment Rule.”
They also know that, in its ruling, the court set forth conditions that will force a revised overpayment rule to be even more complex—making enforcement that much more difficult.
Such a revised rule is very unlikely to be enforced retroactively, even if it survives the inevitable court challenge.
As of now, there is no compliance enforcement where it comes to risk-coding.
None.
Your course of action is clear.
Code.
Get those risk codes submitted. Don’t worry about compliance enforcement, there is none.
I don’t think this is good public policy, but I’m here to help you succeed—not solve the nation’s healthcare woes.
And I’m not advising you to commit fraud or to submit codes for conditions not present or treated in the patient. You don’t want to forget what happened to the town of Lago at the end of High Plains Drifter—the bad guys got their comeuppance from an avenging angel.
But you should be aware that you can walk closer to the line, try out new systems of code collection, and get your RAF scores above 1.2.
The Sheriff has left town and there is no one in sight to replace him.
Act accordingly.