DOJ, CMS issue self-audit guidelines for cardiac implants

The U.S. Justice Department and the Centers for Medicare & Medicaid Services have sent guidelines to hospitals recommending they engage in self-auditing to determine if they have overbilled Medicare regarding implantable cardiac defibrillators, Cardiovascular Business reported.

The guidelines include instructions for hospitals to review claims for implant surgeries that may be considered questionable, and how to estimate potential financial penalties, according to the arti cle. Such implants can cost $40,000 or more, and treble damages could be collected under the False Claims Act.

According to the DOJ documentation, charges for implantable defibrillators are allowable only if the treatment was ordered due to cardiac arrests or ventricular tachyarrhythmia due to a "transient or reversible" cause. Supporting documents, such as ECG or cardiac monitor strips and testimony from the original treating physician, should be available to support claims.

The American Heart Association said the DOJ/CMS guidelines are the result of a collaborative effort with itself and other cardiology interest groups, including the American College of Cardiology and the Heart Rhythm Society.

"We believe that this approach will lead to a major reduction in the implantation of medically unnecessary or inappropriate ICDs," the American Heart Association said late last week in a statement.

For more:
- read the Cardiovascular Business article
- check out the DOJ guidelines (.pdf)
- read the American Heart Association statement

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