Carroll Manor Nursing and Rehabilitation Center

Washington DC, DC 2017 Assisted Living / Long-Term Care
OIG HHS False Claims Act Therapy Billing Without Physician Certification Documentation Deficiencies
Penalty
$2 million

Outcome

Carroll Manor Nursing and Rehabilitation Center in Washington DC paid nearly $2 million after self-disclosing that it submitted Medicare claims for therapy services that lacked required physician certifications for care plans and proper documentation supporting the therapy minutes billed.

Details

Carroll Manor Nursing and Rehabilitation Center (Washington DC) — $2M Penalty for Uncertified Therapy Claims (2017)

Outcome: Carroll Manor Nursing and Rehabilitation Center in Washington DC paid $1,962,227.92 after self-disclosing that it billed Medicare for therapy services without the required physician certifications for care plans and without proper documentation supporting the number of therapy minutes claimed.

Carroll Manor Nursing and Rehabilitation Center, a skilled nursing facility in Washington DC, self-disclosed to the OIG that it had submitted Medicare claims for therapy services (physical therapy, occupational therapy, and/or speech-language pathology) that violated two related documentation requirements: (1) the therapy plans of care lacked physician certification as required by Medicare; and (2) the documentation did not properly support the number of therapy minutes for which claims were submitted.

Medicare requires that skilled nursing facility therapy services be ordered by a physician who certifies the plan of care. Without physician certification, a therapy claim is improper regardless of whether services were actually rendered. This dual documentation failure — missing certifications and unsupported therapy minutes — resulted in the nearly $2 million penalty, settled March 3, 2017.

Primary Source: OIG Enforcement Record

How Crucible Prevents This

Crucible's therapy billing documentation audit controls would detect missing physician certifications before Medicare claims are submitted. Automated verification that each therapy plan of care has a current, signed physician certification — and that billed therapy minutes are supported by therapist documentation — prevents the dual documentation failure that generated this nearly $2 million penalty.

Source: Carroll Manor Nursing and Rehabilitation Center Agreed to Pay $1.9 Million for Allegedly Violating the Civil Monetary Penalties Law by Submitting Claims for Therapy Services Without a Physician Certification

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