CMS offers guidance on DRA's effect on false claims
Health Care Auditing Strategies, December 1, 2007
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CMS has issued two sets of guidance on section 6032 of the Deficit Reduction Act of 2005 (DRA) in light of significant ambiguities in the statute: the State Medicaid Director Letter in the winter of 2006 and a second letter, issued with additional documents for guidance, in the spring of 2007.
CMS guidance winter 2006: State Medicaid Director Letter 06-024
On December 13, 2006, CMS sent a letter to state Medicaid directors to offer guidance on the scope of the DRA employee education requirement.
The letter presents the following clarifications:
An "entity" is inclusive of a "governmental agency, organization, unit, corporation, partnership, or other business arrangement (including any Medicaid managed care organization, irrespective of the form of business structure or arrangement by which it exists), whether for-profit or not-for-profit, which receives or makes payments, under a state plan approved under title XIX or under any waiver of such plan, totaling at least $5 million annually.
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