“The AAFP is troubled that this proposal essentially creates an unfunded requirement that forces medical practices to implement self-audits and internal compliance plans,” wrote AAFP Board Chair Roland Goertz, MD. “Though often recommended business practices, they are time-consuming, expensive and never before required by Medicare. Further troubling is that this considerable burden is not even addressed in the regulatory impact section.”
Dr. Goertz added that the AAFP opposes CMS’ proposal to use a 10-year look-back period for overpayment. The Health Insurance Portability and Accountability Act of 1996 requires physicians to maintain billing records for just six years, he wrote.
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