Medicare Compliance

Civil Monetary Penalties and Handling Conditional Payments

Sam Crepeau, Medicare Compliance Counsel, ISG. Although the specter of CMS imposing Civil Monetary Penalties (CMPs) for Section 111 non-compliance has haunted the MSP landscape since 2007, the intervening time has given all the players an opportunity to launch their respective compliance programs. Now that CMS has issued its Proposed Rule and we await the…