Regulators have made it clear that the long-standing “three patient statements” practice does not satisfy the legal standard for a “regular and customary collection effort.” Behavioral health providers that rely solely on mailing three statements risk violating federal fraud and abuse statutes—including the Anti-Kickback Statute (AKS), Civil Monetary Penalties Law (CMP), Medicare Cost Reporting Requirements, and the Eliminating Kickbacks in Recovery Act (EKRA).
Download this White Paper which includes:
Overview of the 3-Statement Myth
Regulatory Background
Behavioral Health Context
Risks of Non-Compliance
Recommended Action Plan