So we all know millennium did some things they shouldn't (that all other labs were doing as well if not worse) and were sued for it. Since then the whole industry has changed. Medicare came out and said no custom or preselected panels. Is millennium the only lab following this? It seems as if every single major lab other than millennium now, is at least doing something in the grey. Ex. Ameritox- custom profiles Aegis- lab space Castle- pass through billing Avutox- pass through billing Confirmatrix- huge panels (I've even seen them doing eia and confirming the negatives and positives Lab core and quest are even doing preselected panels. I'm obviously biased but has anyone else noticed this? They went after millennium first because they had the most $. But these other labs are blatantly doing this. For ex. I know of several accounts using aegis doing 1000+ specimens a month getting lab space (I know this is grey area) avutox and castles only model has ever been pass through billing with private practices. In my opinion the govt needs to go after these regardless of how much money they can get back. Any other opinions on this?
2016 is going to be an interesting year. Even the mismanaged and now defunct Calloway is being investigated currently.
CMS did not say no custom panels. They only pay 1 fee no matter how many drugs in a panel so they can't dictates this. The doctor ordering must sing off on the panel and state that he requested this to be set up. CMS is trying to not pay for anything but will have a tough time in court fighting the custom panels. If they pay $79 for 1 drug in a screen or 100 drugs in a screen they can't limit you! Just like all the medical necessity bullshit going on. CLIA states that is you receive a sample you have to perform testing on this sample in a timely manner. You can't wait to get medical necessity clarified before testing. A class action lawsuit from all labs doing drug testing, whether criminal or legit is what is needed. I am sick of being accused of being a criminal because of what Millennium did. All rationale from CMS is out the window and all they want is money so Obama can brag about how much he recovered.
What MH did was illegal; giving free cups for docs to make $ on, billing dead people, genetic testing that was not medically necessary and what the government quoted as "over utilization". The lab space rental that Quest, Lab Corp, Aegis and other labs use were written by the OIG and are protected under the "safe harbor". The leases are fair market value of a small space that the collector occupies. You are correct if the leases are done incorrectly it can be viewed as inducement but if done correctly they are a legal best practice to protect both parties.
CMS actually has 4 tiers, $79 being the lowest reimbursement for 1-7 drug classes. I think it would be great if there was only reimbursement rate for as many drugs as you want to test, as long as it was around $150-250. Also, MH had doctors sign a cup agreement stating they would not bill for the services and it was approved from an attorney. I can see how it is possible to accidently bill a few dead people when doing 12,000 specimens a day. Doctors ordered the genetic testing that you say was not medically necessary.
The docs ordered medically unnecessary tests because they were being induced with free POC cups they could makes hundreds of dollars per sample. It was a partnership betweem MH and the client. The government took care of it
The government took care of it? Seriously? Frankly I'm still ticked that MY tax payer money went to the government to PAY for MH's crooked ways! CMS told MH no panels because they cannot play by the rules, period.
MH is on its way out. The CIA and compliance rules will be too much to burden. I understand they are already having to walk away from accounts because they are no longer getting paid. Looks like the $$ has dried up
Calloway shut down and sent faxes to their customers many months ago. If you are a MH rep and they actually have you believing there can be no panels you are still drinking the internal kookaid from NicMo. YOU can't have panels as part of your CIA (corporate integrity agreement). Read it sometime or do they tell you not to do that or go to justice.gov? Sheeple! And yet the message is "we are the first to not do them, we are so compliant." Such BS! You aren't doing it because YOU can't. Read your LCDs!!!
https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=36668&ContrId=362&ver=3&ContrVer=1&CntrctrSelected=362*1&Cntrctr=362&s=All&DocType=Active%7cFuture&bc=AggAAAQAAAAAAA%3d%3d& "Physician-directed definitive profile testing is reasonable and necessary when ordered for a particular patient based upon historical use and community trends. However, the same physician-defined profile is not reasonable and necessary for every patient in a physician’s practice. Definitive UDT orders should be individualized based on clinical history and risk assessment, and must be documented in the medical record. " ^^ Sounds like no profiles to me. I am 100% sure whatever terrible company you work for isn't offering an individualized profile for each patient.
https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=36668&ContrId=362&ver=3&ContrVer=1&CntrctrSelected=362*1&Cntrctr=362&s=All&DocType=Active%7cFuture&bc=AggAAAQAAAAAAA%3d%3d& "Physician-directed definitive profile testing is reasonable and necessary when ordered for a particular patient based upon historical use and community trends. However, the same physician-defined profile is not reasonable and necessary for every patient in a physician’s practice. Definitive UDT orders should be individualized based on clinical history and risk assessment, and must be documented in the medical record. " ^^ Sounds like no profiles to me. I am 100% sure whatever terrible company you work for isn't offering an individualized profile for each patient.
The people working for Millenium defending them are just as bad as the people running the company when they were breaking laws A$$ clowns No defense for that group But keep on trying
