MEDICARE COMPLIANCE
Welcome to Synergy’s blog page dedicated to the topic of Medicare compliance. Our team of Medicare experts share their InSights and knowledge on the latest developments and best practices for law firms to stay compliant with the MSP. Stay up-to-date with the latest trends and strategies to ensure that you have the information you need to navigate the complex world of Medicare compliance. Our blogs provide practical tips and advice for ensuring that your clients receive the medical care they need while complying with Medicare’s requirements. Let our experts guide you through the intricacies of Medicare compliance and help you stay on top of the latest developments in this rapidly-evolving field.
Settlement documents, such as the release, for cases involving Medicare beneficiaries will often contain puzzling boilerplate Medicare Secondary Payer (MSP) compliance terms. At times, you may also see lengthy addendums to the release that appear to have been copied straight from an MSP Act treatise. When reviewing settlement documents, attorneys should focus on some key terms such as those addressing conditional payments and/or Medicare Advantage Organization (MAO) payments, Section 111 Mandatory Insurer Reporting and the avoidance of cost-shifting post-settlement injury-related care to Medicare. Provisions regarding the plaintiff’s waiver of their right to pursue the private cause of action under 42 U.S.C. § 1395y(b)(3)(A) are also common. This article will discuss each of these issues to help you better decipher the MSP compliance terms you may encounter in a settlement.
Reimbursement of Conditional Payments / Medicare Advantage Plan (MAP) Payments
The conditional payment reimbursement obligation stems from the Medicare Secondary Payer Act and implementing regulations. While the Act generally prohibits Medicare from making payment for services to the extent that payment has been made or can reasonably be expected to be made promptly under any of the following “(i) workers’ compensation; (ii) liability insurance; (iii) no-fault insurance”, an exception is made when payment is not expected to be made promptly or within 120 days of receipt of the claim.[1] In such cases, Medicare will make payment, but it is conditioned upon the reimbursement of the payment to the Medicare Trust Fund from a settlement, judgment or award.
Primary payers have an obligation to reimburse the Medicare Trust Fund for any payments made on behalf of a Medicare beneficiary. This obligation is demonstrated by a judgment, payment conditioned upon release of liability, or other means, as enumerated in 42 C.F.R. § 411.22. A failure to reimburse the Medicare Trust Fund may result in Medicare filing suit directly for double damages against any or allentities that were responsible for reimbursement of the conditional payments.[2] Entities may include a beneficiary, provider, supplier, physician, attorney, state agency or private insurer that has received a primary payment.[3] The Centers for Medicare & Medicaid Services (CMS) Memo from December 5, 2011, further notes that Medicare Advantage Organizations (MAOs) and Prescription Drug Plans (PDPs) have the same rights of recovery as Medicare under the MSP Act.
A conditional payment settlement provision will generally place the burden of conditional payment and MAO reimbursements on the injured party. Since a final conditional payment amount is only available after the case is settled (absent the use of the Final Conditional Payment Process), settlement documents that specify an interim conditional payment amount for reimbursement are problematic. Considering this, it is important that the injured party be advised that the final conditional payment number may differ from the number listed in the terms. When investigating reimbursement amounts, keep in mind that the MAO reimbursement amount must be secured from the recovery contractor that has been retained by the specific plan. CMS’ conditional payment information only addresses payments made under traditional Medicare, Parts A and B. Given the exposure that attorneys face when conditional payments and MAP reimbursement claims are missed, a process should be implemented to ensure that the reimbursements are made in a timely manner and inappropriate reimbursement claims properly disputed.
Section 111 Mandatory Insurer Reporting
Attorneys may question the appropriateness of provisions involving the sharing of information for Section 111 Mandatory Insurer Reporting. Section 111 of the Medicare, Medicaid, and SCHIP Extension Act of 2007 (MMSEA) was enacted in order to effectively implement the MSP framework. This enforcement mechanism notifies Medicare of settlements involving Medicare beneficiaries and began in January of 2011. According to CMS, the Section 111 MSP reporting process is designed to ensure Medicare is properly reimbursed for items and services provided to beneficiaries.
Section 111 reporting is the responsibility of a Responsible Reporting Entity (RRE) to Medicare for liability, no-fault, and workers’ compensation plans and insurers. It is not done by the Plaintiff’s attorney. The RRE must report to Medicare if the plan has an Ongoing Responsibility for Medical (ORM) or if the Total Payment Obligation to the Claimant (TPOC) is greater than the threshold of $750.00 for physical trauma cases. Additionally, the RRE must query the Medicare system regularly to identify when a claimant becomes eligible for benefits while the claim is still open.
Under Section 111 reporting requirements, the RRE must provide the injury victim’s first name, last name, date of birth, gender, Medicare Beneficiary Identifier (MBI), and Social Security Number (or the last five digits). Additionally, the RRE must report International Classification of Diseases, Tenth Revision (ICD-10) diagnosis codes for the illnesses/injuries alleged, claimed or released in the Total Payment Obligation to Claimant (TPOC) settlement, judgment, award, or other payment. The TPOC report must also include the date and amount of the settlement. A failure to report under Section 111 reporting may result in civil money penalties being imposed against the RRE.
Given the Section 111 Mandatory Insurer Reporting obligation, it is appropriate for the defense to include a cooperation provision in the settlement terms. Considering the significant role that ICD-10 codes play in the conditional recovery process, parties should be aligned in their selection of codes as well as the accident dates. One way to do this is by adding specific ICD-10 codes to the settlement terms, being careful not to use vague codes or an excessive number of codes.
Post-Settlement Injury Related Care
The MSP Act and supporting regulations specifically state that Medicare is precluded from making payments for services to the extent that payment has been made or can reasonably be expected to be made promptly under any of the following: (i) workers’ compensation; (ii) liability insurance; (iii) no-fault insurance.[4] Given this clear language, workers’ compensation settlements will usually address the post-settlement injury-related care by including the funding of a Workers’ Compensation Medicare Set-Aside (WCMSA) in connection with the settlement. This is appropriate given an employer’s lifetime obligation to pay for the employee’s reasonable, necessary and related medical bills. If CMS’ voluntary review of the WCMSA is available to the parties, the settlement terms may include an agreement to seek review from CMS.
Liability settlements are not the same as workers’ compensation settlements. Although CMS had begun the process of promulgating regulations, the process was aborted. At this time, there is only the language of the MSP Act, and two CMS memos that address liability settlements to provide guidance. Per the May 25, 2011 CMS policy memorandum a/k/a Stalcup memo, “Each (plaintiff) attorney is going to have to decide, based on the specific facts of each of their cases, whether or not there is funding for future medicals and if so, a need to protect the Trust funds.” The second memo is from September 30, 2011 and is known as the Benson memo. It notes that when a treating physician completes a written certification that the injury-related treatment has been completed and no further injury-related care is indicated, Medicare considers its interest, with respect to future medicals for that “settlement” satisfied.
Absent rules from CMS on liability settlements, the language of the MSP Act and Medicare’s prohibition from making payment in certain situations should be considered. When a liability settlement contains an element of future injury-related treatment, a Medicare beneficiary plaintiff may choose to “set aside” funds from the net settlement for this treatment. This complies with the goal of the MSP Act, which is the preservation of the Medicare Trust Fund. On the other hand, parties may at times just add a settlement provision that indicates there is no intention to cost shift post settlement injury related care to Medicare and that Medicare has no interest in the settlement. The decision of whether to “set aside” funds in a liability settlement is an individual one and depends on the specific facts of the case. When reviewing liability settlement terms that address future injury-related care, watch for contingencies that cannot be met, such as having CMS review a liability MSA.
Private Cause of Action Waiver
It is not unusual to see settlement terms that include the plaintiff’s agreement to waive their right to bring a private cause of action. The private cause of action is related to the obligation to reimburse Medicare for conditional payments and MAO plans for their payments. In order to enforce this obligation, Medicare beneficiaries, and others with standing, may bring an action against a party for double the amount owed to Medicare. This right comes from the MSP Act which states: “There is established a private cause of action for damages (which shall be in an amount double the amount otherwise provided) in the case of a primary plan which fails to provide for primary payment (or appropriate reimbursement) in accordance with paragraphs (1) and (2) (A).”[5]
The agreement to waive the private cause of action may not be of consequence when the parties intend to and actually address the conditional payments and MAO payments. The decision of whether or not to agree to this waiver however is up to the plaintiff’s attorney.
Conclusion
Attorneys should focus on key MSP compliance areas when reviewing settlement documents: conditional payments and MAO reimbursements, Section 111 Mandatory Insurer Reporting, and post-settlement injury-related care. Proper understanding and handling of these terms can protect both the firm and the client from future liability. Moreover, MSP compliance experts, such as those at Synergy, can assist in crafting strategies to ensure compliance and mitigate risks. Contact us today.
[1] 42 U.S.C. § 1395y(b)(2)(A)(ii); 42 C.F.R. § 411.20(a)(2).
[2] 42 U.S.C. § 1395y(b)(2)(B)(iii); 42 U.S.C. § 1395y(b)(3).
[3] 42 C.F.R. § 411.24.
[4] 42 U.S.C. § 1395y(b)(2)(A)(ii); 42 C.F.R.§411.20(a)(2)).
[5] U.S.C. § 1395y(b)(3)(A).
By: Rasa Fumagalli, JD, MSCC, CMSP-F | Director of MSP Compliance Services
Introduction
Effective lien resolution is pivotal in personal injury cases. Liens—claims from healthcare providers, insurers, or government agencies against a plaintiff’s settlement—can significantly impact the net recovery. Understanding and managing these liens is crucial for maximizing the client’s recovery and ensuring compliance with legal requirements.
What is a Lien?
In personal injury cases, a lien represents a claim by an entity seeking reimbursement for medical expenses or benefits provided to the injured party. These claims must be addressed to avoid compromising the client’s net settlement.
Overview of Various Lien Types
Medicare Liens Conditional Payments: Medicare’s conditional payments for medical expenses necessitate reimbursement from settlement proceeds under the Medicare Secondary Payer Act. The resolution process is managed by the Medicare Secondary Payer Recovery Contractor (MSPRC), which involves reporting the settlement to the MSPRC and resolving the reimbursement obligation with them through their normal process.
Medicare Advantage (Part C) Liens: Medicare Advantage plans, administered by private insurers, can assert liens for covered medical expenses. To resolve, you negotiate directly with the private insurer or their recovery contractor. The process is governed by the same laws as traditional Medicare but involves private insurance entities.
Medicaid Liens: Medicaid liens are asserted by state programs for medical expenses paid on the plaintiff’s behalf, with each state having distinct laws. To resolve, you contact the state Medicaid agency to determine the lien amount, negotiate reductions, and comply with state-specific procedures.
ERISA Liens: ERISA liens arise from employer-sponsored plans, often with strong subrogation rights if self-funded. In resolving these liens, first understand the ERISA plan terms, then engage with the plan administrator, and negotiate reductions under federal law (if self-funded), which can be complex. If the plan isn’t self-funded, then state law will apply.
FEHBA/Military Liens: FEHBA and military plans like TRICARE may assert liens for medical expenses. To resolve, contact the relevant federal agency or military plan administrator to understand lien rights and negotiate reductions where feasible.
Private Health Insurance Liens: Private insurers may assert subrogation claims based on their policy’s provisions. To resolve, first review the insurance policy, then negotiate directly with the insurer, and argue for reductions based on equitable principles or other legal related arguments for reduction based upon state law.
Hospital and Provider Liens: Hospitals and providers may assert direct liens for unpaid medical bills. To resolve, negotiate with providers, leveraging financial hardship or equitable distribution arguments, and the reasonable cost of care.
Conclusion
Navigating the complexities of various liens requires a thorough understanding of their unique characteristics and resolution processes. From Medicare to ERISA and military liens, each type demands specific strategies for effective resolution. Understanding these nuances ensures that personal injury lawyers can protect their clients’ interests and secure the highest possible net recovery.
If you want to do further reading on the subject, our white paper is a detailed guide to the different lien types and all of their nuances. You can download “Advanced Lien Resolution Techniques – Medicare, Medicare Advantage, Medicaid, ERISA, FEHBA, Military Liens and Hospital Liens” by clicking HERE. If however you are ready to partner with Synergy and outsource lien resolution today, contact us NOW.
Written by: Jason D. Lazarus, J.D., LL.M., MSCC | CEO
Correctly navigating Medicare’s conditional payment resolution process is critical for personal injury attorneys, given the complex legal framework and the substantial risks involved in failure to reimburse. Under the Medicare Secondary Payer Act (MSPA), the Centers for Medicare & Medicaid Services (CMS) have broad powers to recover payments made on behalf of Medicare beneficiaries, including the right to sue trial attorneys directly. Failing to address Medicare’s reimbursement claims correctly can lead to severe financial and legal consequences for personal injury law firms.
MSPA: The Legal Framework
CMS can recover conditional payments from any entity that touches settlement dollars which are meant to reimburse medical expenses, including attorneys who handle personal injury settlements. The case of U.S. v. Harris starkly illustrates the potential pitfalls. In this case, a personal injury attorney was held liable for Medicare’s conditional payments despite settling a claim and notifying Medicare. The court ruled against the attorney, emphasizing that CMS’s rights under 42 U.S.C. § 1395y(b)(2) extend to recovering from entities that have received payments from primary plans, a personal injury law attorney.
A Labyrinth: The Medicare Resolution Process
Resolving Medicare’s conditional payments involves several steps:
- Initial Reporting: Contact the Benefits Coordination & Recovery Contractor (BCRC) before settlement to obtain a Conditional Payment Letter (CPL). This letter is preliminary and should be audited to remove unrelated care.
- Final Demand: After settlement, Medicare must be informed, and a Final Demand will then be issued. Payment must be made within 60 days to avoid interest accumulation and potential enforcement actions by the DOJ.
Mistakes to Avoid: Common Pitfalls
There are some common mistakes made by personal injury law firms when it comes to conditional payments. These mistakes can be costly, and it is best to avoid them:
- Relying on Conditional Payment Letters: Conditional Payment Letters are not final. Only a Final Demand Letter from Medicare confirms the amount due and is binding. Relying on preliminary figures can lead to significant shortfalls and legal issues, as evidenced by a 2019 case where a Maryland law firm settled a claim which was based upon reliance on incorrect figures in a Conditional Payment Letter.
- Improper Resolution Channels: Using incorrect methods to resolve conditional payments, such as state court proceedings instead of the required administrative processes, can result in severe repercussions, as seen in a Texas case where a state court ruling was sought to reduce what was owed to Medicare which wasn’t effective. Instead, the trial attorney was sued by the government for failure to properly reimburse Medicare.
Reducing What is Owed: Appeals, Compromises, and Waivers
When dealing with Medicare’s repayment formula, attorneys face a rigid calculation per the applicable regulation. The calculated repayment amount often doesn’t account for case-specific details impacting the recovery such as liability issues or policy limits. To address this fact, attorneys can:
- Appeal: Navigate through Medicare’s multi-level internal appeal process, which is lengthy, and interest accrues during the appeal. Or.
- Request Compromise/Waiver: After paying the Final Demand, attorneys can request a compromise or waiver, potentially leading to a refund. Requests can be made under:
- Section 1870(c): Financial hardship waiver.
- Section 1862(b): Best interest of the program waiver.
- Federal Claims Collection Act: General compromise request.
Conclusion
Effective resolution of Medicare conditional payments requires diligence and adherence to proper processes prescribed by Medicare. Attorneys should avoid relying on preliminary figures, ensure timely and accurate reporting, and use appropriate channels for appeals or compromise/waiver requests. Understanding and navigating Medicare’s complex requirements is crucial to safeguarding against personal liability and ensuring successful settlement outcomes.
Working with specialized lien resolution companies can provide essential expertise and prevent costly mistakes when it comes to Medicare conditional payments. If you want to find out more, contact us today to Partner with Synergy for lien resolution.
Written by: Jason D. Lazarus, J.D., LL.M., MSCC | CEO
Navigating Medicare compliance is a critical task when handling personal injury settlements involving Medicare beneficiaries. Ensuring total compliance with the Medicare Secondary Payer Act (MSP) requires a strategic approach and thorough understanding of the law/regulations. This blog post is a basic guide for trial lawyers when it comes to Medicare Secondary Payer compliance.
Identifying and Reporting Medicare Beneficiaries
The first step in Medicare compliance is to identify clients who are current Medicare beneficiaries or those reasonably expected to become beneficiaries within 30 months. Implement a screening method to flag these cases within your firm. Once identified, contact Medicare and report the settlement to obtain a Conditional Payment letter and ultimately a Final Demand. Carefully audit the Conditional Payment Letter and use the compromise/waiver process to achieve further reductions post payment of the Final Demand. Additionally, identify and resolve any Part C/Medicare Advantage Organization (MAO) liens.
Release Language
Release language is a vital component in Medicare compliance. Avoid overbearing or irrelevant language that can negatively impact your client. For example, make sure that the release doesn’t take away specific rights related to their government benefits. Also, ensure the release does not make the settlement contingent on CMS approval or other requirements that have no legal basis.
Early Intervention and Collaboration
Start the compliance process early in your case. Confirm disability eligibility with Social Security and gather all relevant insurance and government assistance documentation. Collaborate with opposing counsel on the information reported under the Mandatory Insurer Reporting (MIR) requirements. Ensure proper ICD codes are included to avoid future Medicare claim rejections.
Advising Clients on Medicare Futures Implications – Education and Expert Consultation
When dealing with Medicare beneficiaries, it’s crucial to assess whether future medical expenses are being paid as part of the settlement. If so, then: Consult, Advise and Document.
Educate your clients about the impact of not setting aside funds for future Medicare-covered expenses. Proper documentation of all compliance steps is crucial. Consult with experts to navigate the complexities of the MSP, including lien identification, conditional payment resolution, MSA creation, and release language. Expert guidance is essential to avoid mistakes that could lead to client dissatisfaction or legal malpractice claims.
If clients opt out of creating a Medicare Set-Aside (MSA), ensure they acknowledge the implications in writing. For those who choose to create an MSA, work with specialized companies like Synergy to perform the analysis and document the process accurately.
Avoid Complications at Settlement
The key takeaway is to manage Medicare compliance issues proactively to avoid disputes that could land you in federal court. Ensure proper ICD codes are reported and evaluate the necessity of an MSA with your client. Collaborate with experts and consider the potential for using the MSA as a negotiation tool to enhance settlement value. Carefully word the release to protect your client’s interests and avoid inappropriate language.
Conclusion
By following these steps, you can achieve total Medicare compliance, safeguard your clients’ interests, and navigate the complexities of the MSP with confidence. Proper planning and expert consultation are paramount to ensuring a smooth settlement process and avoiding legal pitfalls.
Turn to Synergy for experts who can help create a Medicare compliance strategy for your firm to mitigate liability risks and protect clients. Inadequate compliance processes can result in financial liabilities and worse yet damage to your firm’s reputation. Having a Synergy expert perform a Medicare Expert Case Evaluation (MECE) helps you educate your client related to future potential denial of care and then document your file appropriately. Ensure your Medicare processes protect both your clients and your practice by partnering with Synergy for total Medicare compliance.
Written by: Jason D. Lazarus, J.D., LL.M., CSSC, MSCC
Guest blog
When you visit a doctor, you expect a certain level of care. This comes from both the doctor and your health care coverage provider such as Medicare. Unfortunately, patients do not always receive the care they deserve, but when this happens, who is at fault? Is it the doctor’s office, or is it Medicare?
In some cases, one or the other fails to serve their patients properly. Sometimes it can even be both parties. As a medical malpractice lawyer can share, there are certain cases where it is difficult to determine fault, but a knowledgeable attorney can guide you through the process in order to get you the compensation you deserve.
A lawyer will examine all parties involved in your case, and they will be able to determine who was the at-fault party. Our friends at Cohen & Cohen are here to shed some light on examples of issues you might face from doctors versus Medicare so that you can be well-informed and prepared in case these incidents happen to you.
Discrimination
No kind of discrimination is tolerated within Medicare. This includes sex, gender, race, and more. At any time, if you believe this is what is happening to you, it is best to contact a lawyer for help. However, when it comes to discrimination it is most times at the level of your actual care provider and not your coverage provider. This means the doctors treating you are more likely to be at fault than Medicare. There are rare instances, however, where discrimination can occur within the Medicare system.
Privacy
You have a right for your medical records to be kept private unless you designate that they may be shared with another party. There might be a time when your records are shared without your consent. If your records are shared, this is a legal violation. It is Medicare’s duty to ensure the businesses they work with protect your information. If Medicare is found to have been negligent in this aspect, you may have a case. Oftentimes it is the actual doctor’s office that is at fault because they are the ones physically sharing the information, but if Medicare knew that a doctor had been sharing information and did nothing about it, this is where fault becomes tricky to establish.
Questions
A large part of Medicare is that you have the right to have your questions about the services rendered by Medicare answered. After all, if you do not know what is covered, then you may find yourself with a large hospital bill you were not planning on having. This scenario is extremely rare, but it can happen — and if you are directly asking the questions to Medicare and notice they are not answering you, then it is time to seek legal help.
In essence, you have a right to be treated fairly, have your privacy protected, and have all of your questions answered. These are a few of the basic premises upon which Medicare operates. If any of these are violated, it is time to seek an attorney. Even if you are not sure whether your issues stem from Medicare or your doctor, it is best to seek legal counsel to understand what your options are. Contact a lawyer near you today for more information.
By Jason D. Lazarus, J.D., LL.M., MSCC
When representing a Medicare beneficiary, personal injury law firms should prioritize compliance with the Medicare Secondary Payer Act (MSP). Inadequate compliance processes can lead to severe consequences, including government actions against the firm. This blog post outlines the risks and best practices related to MSP compliance to safeguard both your firm and your clients.
Government Actions for Non-Compliance
The government’s enforcement of the MSPA is evident in several cases where personal injury law firms faced significant monetary liability for non-compliance:
Harrisburg, August 2020: A law firm paid $53,295 to resolve liability for non-repayment of Medicare conditional payments in a malpractice case against a pharmacy.
Philadelphia, January 2020: Another firm settled allegations of failure to reimburse Medicare by agreeing to pay $6,604.59, implementing compliance practices, and acknowledging potential liability under the False Claims Act.
Baltimore, November 2019: A law firm paid $91,406.98 to resolve allegations of failure to pay back Medicare, emphasizing that joint representation and referral cases must also comply. You can’t refer a case and be absolved of liability.
Maryland, March 2019: A firm settled for $250,000 due to reliance on an incorrect conditional payment letter rather than a final demand from Medicare.
Philadelphia, June 2018: A firm settled for $28k and agreed to initiate a compliance program as part of a settlement which was according to the US Attorney meant to remind attorneys of their obligation to reimburse Medicare.
These cases underscore the government’s commitment to bringing legal actions to recover Medicare dollars from personal injury law firms and holding attorneys accountable for non-compliance, regardless of the circumstances.
Best Practices for MSP Compliance
To navigate the complex regulatory landscape, personal injury law firms can adopt best practices for Medicare compliance. Firms should:
- Identify Medicare Beneficiaries: Establish processes to determine if clients are Medicare beneficiaries early in the representation.
- Understand Reporting Requirements: Make sure to appropriately report representation to Medicare and be aware of the medical information and ICD codes reported by defendant insurers under the Mandatory Insurer Reporting law (MIR) created by MMSEA.
- Appropriate Release Language: Avoid agreeing to inaccurate or onerous Medicare compliance language in settlement documents prepared by the other side.
- Resolve Conditional Payments: Ensure timely reporting and resolution of conditional payment obligations to avoid personal liability.
- Utilize Compromise and Waiver Processes: Implement procedures to reclaim funds from Medicare when appropriate.
- Educate Clients: Inform clients about Medicare compliance issues, especially regarding potential denial of future injury-related services.
- Monitor Liens: Be vigilant about identifying and addressing all Medicare liens, including those from Medicare Part C lien holders.
Implementing a Compliance Strategy
Client education for those who are Medicare eligible is the cornerstone of a successful Medicare compliance strategy for law firms. Lawyers and their staff must be well-informed about MSP-related issues to identify potential problems before they escalate into malpractice claims or personal liability. Outsourcing to a strategic partner who has deep expertise in the Medicare Secondary Payer Act should also be considered. Developing a systematic approach to handle Medicare beneficiaries and related compliance concerns is essential for protecting both clients and the firm’s integrity.
Conclusion
The government’s enforcement of the Medicare Secondary Payer Act highlights the necessity for personal injury law firms to ensure MSP compliance thoroughly. Non-compliance can result in significant monetary consequences, personal liability, and damage to the firm’s reputation. By adopting best practices and ensuring thorough firm-wide processes, law firms can navigate the complexities of Medicare compliance, safeguarding their practice and serving their clients effectively.
Turn to Synergy for experts who can help create a Medicare compliance strategy for your firm to mitigate liability risks and protect clients. Inadequate compliance processes can result in financial liabilities and worse yet damage to your firm’s reputation. Ensure your Medicare processes protect both your clients and your practice by partnering with Synergy for total Medicare compliance.
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