| 1990 – 2007 |
CMS / CPA AUDITS:
"19 years of flawless CMS field and desk audits and unqualified opinions from clients’ CPA firms." |
| 1994 |
ORIGINAL HCFA / CMS OPINION:
“….. the Quest product incorporates software developed and maintained by HCFA or its contractors, such as Grouper and Price programs, it does not violate Medicare rules and regulations.” |
| 2002 |
OIG / HIPAA / CMS VALIDATION:
“……..maintains Protected Health Information Associate Agreements with clients within OIG and HIPAA compliance guidelines, as the software continues to be congruent with the CMS required software programs, (1) the CMS 837 billing format and (2) the HIPAA X-12 data transmission format.” |
| 2003 |
CMS PROVIDER REIMBURSEMENT REVIEW BOARD DECISION:
“Thus, it appears settled that a hospital may charge outpatients a different fee for a service than is charged to inpatients, as long as it does not differentiate by payer source.” |
| 2003 |
INDEPENDENT LEGAL OPINION:
Venable LLP, Baltimore MD
(1) “There is no express prohibition on charging hospital inpatients and hospital outpatients a different fee for the same service”.
(2) “There is no express prohibition on charging hospital inpatients a different fee for the same service based on the relative weight or severity of illness as indicated by the corresponding DRG”. |
| 2007 |
INDEPENDENT LEGAL OPINION CONFIRMATION:
Venable LLP, Baltimore MD
“We affirm our prior conclusion because no PRRB decision, or case law or regulation have contradicted it since our Prior Opinion. Nothing in the events that have transpired since our Prior Advice ( of 2003 ) negates the advice we previously gave as to the permissibility of differential hospital charges. |
