Final Rule Clarifications and Revisions
The Final Rule also contains other clarifications and revisions in areas such as:
- Calculating time periods and deadlines
- Provider hearing rights
- Requests for a good cause extension for requesting a hearing
- Group appeals
- Amount in controversy
- PRRB jurisdiction
- Expediting judicial review
- Parties to the proceeding
- Quorum requirements
- Discovery and subpoenas
- Record of administrative proceedings
- Actions in response to the failure to follow PRRB rules
- Scope of PRRB's authority in hearing decisions
- Administrator review
- Judicial review
- Reopening procedures
Finally, in the preamble to the Final Rule, CMS indicates that, to the extent there is a conflict between the provisions of the Final Rule and the PRRB's current instructions, the former will control.
Excerpted from "Medicare Update: Medicare Compliance, Reimbursement, and Enforcement Resource" by Michael Apolskis. In the course of his legal practice, Apolskis works with health care providers, suppliers and companies on a variety of legal and regulatory matters, including Medicare compliance, reimbursement and enforcement matters.
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Publication Date: Friday, September 11, 2009