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Volume 21.04

This week Ryan Lindsay, CPA, Director at The Health Group, LLC, spoke at the Annual Meeting of the National Hospice & Palliative Care Organization (“NHPCO”).  His presentation, “Amazon Will Change How Hospices Do Business”, was reported on by Hospice News.  Ryan’s presentation focused on numerous issues including how disruption in the larger healthcare system could impact hospice and palliative care providers.


The 2020 Financial Management Conference conducted by the National Association for Homecare & Hospice (“NAHC”), scheduled for August 1-3, 2021 in Chicago, will be a live in-person event.  We hope to see many of you in Chicago as programs move once again to in-person events.


For years, The Health Group, LLC has been monitoring the development of CMS’s “Program Integrity Enhancements to the Provider Enrollment Process” and on March 24, 2021, CMS released MLN SE21003.

The MLN provides general information relating to the implementation of Medicare enrollment disclosures relating to affiliation that, in the opinion of CMS, leads to the determination of undue risk of fraud, waste, or abuse caused by disclosable (reportable) events including:

  • Currently having an uncollected debt to Medicare, Medicaid, or CHIP,
  • Has been or is subject to a payment suspension under a Federal health care program regardless of when the payment suspension occurred or was imposed,
  • Has been or is excluded by the Office of the Inspector General (OIG) from participation in Medicare, Medicaid, or CHIP, or
  • Has had its Medicare, Medicaid, or CHIP enrollment denied, revoked, or terminated.

Reportable events will be reportable by the provider, including those by affiliated entities including:

  • A 5 percent (5%) or greater direct or indirect ownership interest that an individual or entity has in another organization,
  • A general or limited partnership interest (regardless of the percentage) that an individual or entity has in another organization,
  • An interest in which an individual or entity exercises operational or managerial control over, or directly or indirectly conducts, the day-to-day operations of another organization (including, for the purposes of the affiliation requirement only, sole proprietorships), either under contract or through some other arrangement, regardless of whether the managing individual or entity is a W-2 employee of the organization,
  • An interest in which an individual is acting as an officer or director of a corporation, or
  • Any reassignment relationship under 42 Code of Federal Regulations (CFR) Section 424.80.

The MLN states that “In light of the pandemic and various other factors, we will not begin updating the Form CMS-855 applications with affiliation disclosure sections for at least another 12 months.”