Corporate Compliance

ESRD conditions of coverage

Compliance Monitor, April 1, 2005

Q: What sanctions might a provider face if it is not in compliance with the new Medicare end stage renal disease (ESRD) conditions of coverage?

A: The possible penalties for noncompliance include

  • termination of Medicare coverage
  • alternative sanctions, such as
    • denial of payment for services furnished to Medicare patients first accepted for care after the effective date of the sanction
    • reduction of payments for all ESRD services furnished to Medicare patients by 20% for each 30-day period after the effective date of the sanction
    • withholding of all payments, without interest, for all ESRD services furnished to Medicare beneficiaries
  • This question was answered by Carrie L. McGinnis, RN, MBA, chief executive officer of Healthcare Design Specialists, LLC, in Springfield, MO.

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