Judith Waltz Examines Medicare Exclusions and Billing Privilege Revocations

Foley & Lardner LLP partner Judith Waltz was quoted in Report on Medicare Compliance after speaking at the Health Care Compliance Association conference, where she discussed the potential consequences of Medicare exclusions and billing privilege revocations.

Waltz analyzed the scope of Centers for Medicare & Medicaid Service’s (CMS) authority, explaining that the delegation allows the agency to “get rid of individuals” who might not directly bill Medicare or other federal health care programs.

She emphasized revocations of Medicare billing privileges can have significant “collateral consequences,” including potential overpayments, loss of hospital or other privileges, actions by commercial payers, and potential liability for providers, facilities, and group practices. Waltz further noted that in certain jurisdictions, the CMS has applied a clinician’s billing privilege revocation to the Part A facility fee, extending the potential impact to health care organizations.