How fitting it was signed on April Fool’s Day.
Friday, April 04, 2014
Thursday, April 03, 2014
CSHM and Small Smiles Dental Centers sign Exclusion Agreement
OIG Excludes Pediatric Dental Management Chain From Participation in Federal Health Care Programs
April 3, 2014
Related Information
CSHM, LLC, formerly known as FORBA Holdings and Church Street Health Management (CSHM), signed an Exclusion Agreement that bars CSHM from participating in Medicare, Medicaid, and all other Federal health care programs for a period of 5 years, Daniel R. Levinson, Inspector General of the U.S. Department of Health and Human Services, announced today. The exclusion is based on CSHM's alleged material breaches of its Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG). CSHM manages and operates the national chain of Small Smiles Dental Centers, which provides services primarily to children on Medicaid. CSHM's corporate predecessor entered into the CIA in 2010, as part of the resolution of a False Claims Act case involving allegations that the company had provided dental services to children on Medicaid that were medically unnecessary or failed to meet professionally recognized standards of care.
To minimize immediate disruption of care to the hundreds of thousands of children treated at CSHM clinics and to enable an orderly, controlled shutdown of the company or divestiture of its assets, the exclusion will be effective on September 30, 2014. CSHM waived its right to appeal this exclusion in any judicial forum.
"CSHM has committed repeated and flagrant violations of its obligations under the CIA—violations that put quality of care and young patients' health and safety at risk," said Inspector General Levinson. "This exclusion underscores our commitment to enforcing our integrity agreements designed to promote quality of care and protect patients in Federal health care programs." Mr. Levinson said that this exclusion "makes clear to the provider community that OIG closely monitors our CIAs, critically evaluates providers' representations and certifications, and will pursue exclusion actions against providers that fail to abide by their integrity agreement obligations."
On March 7, 2014, OIG issued a Notice of Exclusion to CSHM based upon numerous material breaches of its obligations under the CIA. CSHM failed to report serious quality-of-care reportable events, take corrective action, or make appropriate notifications of those events to the State dental boards as required by the CIA, OIG found. CSHM also failed to implement and maintain key quality-related policies and procedures, comply with internal quality and compliance review requirements, properly maintain a log of compliance disclosures, and perform training as required by the CIA. Finally, CSHM submitted a false certification from its Compliance Officer regarding its compliance with CIA obligations.
This exclusion marks the culmination of a series of alleged failures by CSHM and its corporate predecessors to comply with its CIA. Under the CIA, an independent quality monitor conducted more than 90 site visits and reviews to monitor CSHM's compliance. Since the 2010 settlement, OIG repeatedly cited CSHM and took actions to address those violations, promote improved compliance, and maintain access to care for an underserved population. These actions included imposing financial penalties and forcing the divestiture of one of the company's clinics.
Despite these actions, CSHM remained in material breach of its CIA and OIG issued Notices of Intent to Exclude to the company in December 2013 and January 2014. In such cases, providers have the opportunity to demonstrate to OIG that they have cured, or are in the process of curing, the material breaches. CSHM represented to OIG that it would cure the material breaches. However, through meetings with CSHM and its Board of Directors and review of its written submissions, OIG determined that CSHM had failed to cure the material breaches and proceeded with the exclusion.
Until the exclusion goes into effect on September 30, 2014, an independent monitor will continue to monitor the quality of care being provided to patients at CSHM clinics. CSHM is required to inform patients at least 30 days before closing a clinic. CSHM is also required to keep State Medicaid agencies abreast of developments and provide monthly status reports to OIG. Any divestiture of assets by CSHM must be through bona fide, arms-length transactions to an entity that is not related to or affiliated with CSHM.
The Inspector General credited Special Agents from OIG's Office of Investigations, Miami Regional and Nashville Field Offices, with assisting in this investigation. OIG was represented in the investigation and litigation of this matter by Senior Counsel Felicia E. Heimer, Maame A. Gyamfi, Robert M. Penezic, and Tamara T. Forys, with assistance from Paralegal Mariel Filtz.
CSHM disputed OIG's determination that it was in material breach of the CIA.
Monday, March 31, 2014
NCDR–Kool Smiles and Resolution Dental says “main concern is financial”
Kristina Dorsey, HR Manager for NCDR, LLC - Kool Smiles PC & Resolution Dental, admits the main concern to the CEO’s and CFO’s is financial; truer words were never spoken.
(Clip taken from interview on why they hired ADP to help them with the UnAffordable Care Act.)
Thursday, March 27, 2014
HHS-OIG Report - Questionable Billing For Medicaid Pediatric Dental Services in New York–March 2014
This same study could be done in any state these private equity owned dental clinics operate and the results would be the same, if not worse. All of this has been reported right here since 2007, it’s 2014! Just saying…
Questionable Billing For Medicaid Pediatric Dental Services in New York - March 2014
Wednesday, March 26, 2014
Small Smiles Dental Centers in yet another Federal Report due out today
A new federal report will be released Wednesday showing that shady dentists and orthodontists billed the state's Medicaid program for questionable procedures on children. One dentist claimed to have provided one child 42 tooth fillings in a single visit.
BY Glenn Blain NEW YORK DAILY NEWS ALBANY BUREAU|Wednesday, March 26, 2014, 12:20 AM
The state’s Medicaid program paid through the teeth for questionable billings by shady dentists and orthodontists, a new federal report charges.
One dentist claimed to have provided one child 42 tooth fillings in a single visit.
Another dentist averaged 16 procedures per child, compared with a statewide average of five, according to the report, which is being released Wednesday.
They were among 23 pediatric dentists and six orthodontists in the state who pocketed $13.2 million in Medicaid payments in 2012 for services that appeared unnecessary or may not have been performed at all, according to the report by the Department of Health and Human Services inspector general.
“We found one orthodontist who treated almost 5,000 children in a single year,” said Lucia Fort, an analyst in the inspector general’s office.
“That’s about 10 times higher than the state average for orthodontists.”
Read the complete NY Daily News Story here.
CSHM/Small Smiles Dental has been changing the business entity names on file with the Secretary of State in Kentucky and Ohio. Small Smiles of Akron, LLC – Michael Crites, DDS has been changed to Akron Smiles Youth Dentistry, LLC – Michael Crites, DDS. (if you would like a look at the many name changes in Ohio, search the Secretary of State site here using “Prior Business Name”)
Small Smiles of Louisville, PSC was changed to Louisville Smiles Youth Dentistry, PCS on November 27, 2013. Since at least June of 2013,
CSHM has also been changing information contained in their dentists National Provider Identifier (NPI) records on file with the Federal government. The mailing address has also been changed in the individual clinic records. The business mailing address has been changed to a US Postal Service sub-station post office box:16 Arcade Unit 198747, Nashville, TN 37219-1994.
The “manager of licensing and credentialing, Ms. Jenell Stringer is making the changes. I’m sure at the direction of someone at CSHM headquarters.
For instance, on June 11, 2013, Ms. Jenell Stringer, Manager of Licensing and Credentialing changed the mailing address in the NPI record of Small Smiles of Worcester, LLC d/b/a Straight Smiles of Worcester-(NPI number 1487943635) to:
16 Arcade Unit 198747
Nashville, TN 37219-1994
615-750-0343
You can see for yourself by searching the NPI number here.
They did the same thing in May of 2010, just 4 months after the Corporate Integrity Agreement was put into place. At that time I believe they used a US Postal Service sub-station at 208 W. 8th Street, Ste 810,Pueblo, Colorado, 81003-3038
If you would like to check out the dentist records, click here. Below are a few names and NPI numbers:
- Merlin L. Cherian, DMD – 1922348507
- Elizabeth Kay Geier, DDS – 1134251127 (Elizabeth is the “owner dentist” of the Louisville, Kentucky clinic and some in Ohio, along with long time puppet, Dr. Jodi Kuhn, who now has her name slapped all over the clinics in Colorado.)
- Harry Huger Houston, III, DDS – 1003991050
- Todd Bernard, DMD – 1336572791
- Sujani Vellanki, DMD – 1740562610 (apparently she practices dentistry at the post office, since the physical address on her location is also 16 Arcade, Until 198747, Nashville, TN)
Saturday, March 15, 2014
Interview with Gary Iocco, President, National Association of Dental Laboratories
Interview with Gary Iocco, President,
National Association of Dental Laboratories
March 2014
By: Michael W Davis, DDS
NADL Website http://www.nadl.org/home-page.cfm
National Board of Certification in Dental Laboratory Technology http:///www.nbccert.org
The Foundation for Dental Laboratory Technology http://www.dentallabfoundation.org
NADL What’s in Your Mouth http://www.whatsinyourmouth.us
Questions
Dr. Davis: Many in the general public may not know the vital role of the dental technician, within the dental team. From my perspective as a restorative dentist, a dental technician can make me look like a superstar, or a nitwit. What exactly does a dental technician do, and why is that so critical in successful clinical results for patients?
Mr. Iocco: As dental laboratory technology professionals we transform the dentist’s directions from the prescription or work order and create the actual treatment option that the dentist has chosen to provide their patient. Quality dental laboratory professionals employ knowledge of modern materials and available technologies to provide our dentist clients with a restoration that is consistent with the high standard of care and esthetics that our dentists expect to provide for their patients.
This is only possible if there is sufficient communication and understanding and a mutual knowledge of and commitment to what is required for a quality outcome.
While good communication is always important, the more complex or involved a case is the earlier in the planning process a dentist should bring their dental laboratory technology professional into the conversation.
Highly skilled and experienced dentists will tell you that to provide the standard of care and esthetics that they seek for their patients restorations, they work closely with a quality dental laboratory.
Friday, March 14, 2014
Oh where, oh where did it go: CSHM’s Press Release
If anyone is looking for CSHM and Small Smiles press release after the media exposed the fact they will be excluded from Medicaid in 30 days, you won’t find it on their website any longer. No need to put out an “All Points Bulletin”, it can be found below.
President and CEO David R. Wilson, released a memo to payors on March 12, it has since disappeared from their website as well. But never fear,it’s still here.
The whole media statement, from start to finish, basically gave the finger to HHS-OIG and every person who has investigated them since 2007; in addition to making highly misleading—if not down right lying—to staff and employees.
Seems their Facebook page has disappeared as well. I imagine they don’t want any comments or questions, don’t you?
Below is the press release.
March 11, 2014
CSHM, LLC & OIG NOTICE OF EXCLUSION
In a letter dated March 7, 2014, CSHM, LLC (“CSHM”) received a notice of exclusion from federal health care programs from the Office of Inspector General of the Department of Health and Human Services (OIG). The notice of exclusion does not apply to any individual employee or the Dental Centers and Practice Owners, but to the CSHM, LLC corporate entity only. If the exclusion should go into effect, it means that CSHM may not continue with some or all of its current responsibilities under its Management Service Agreement (MSA) and this may affect administrative services related to Center operations.
The exclusion notice is based on the OIG’s determination that CSHM has violated some terms of the Corporate Integrity Agreement (CIA) that has been in place for the management company and its predecessors since January 2010. CSHM assumed the CIA in June 2012 and it is well known that it has implemented the CIA provisions within the Centers and generally since that time. Many Center owners and employees have met the Independent Quality Monitor (IQM) and CSHM’s compliance staff over the last 18 months as the company was implementing the CIA’s provisions. Generally, the alleged violations related to certain delayed reporting of a few adverse clinical events, failure to undertake certain training in 2012 before CSHM assumed the CIA, and the omission of two adverse events on the CIA disclosure log, though over 1,200 events were successfully place on the disclosure log for processing.
CSHM believes strongly that it has substantially and in good faith implemented the CIA at a great cost in resources and with the important cooperation of the Centers and its health care professionals, particularly on the enhancing dental clinical standards. The OIG’s proposed determination to exclude CSHM for some non-compliance with its CIA is an unduly harsh and an unprecedented response to expected and common difficulties in implementing a very complex CIA that has a novel and innovative administrative, process and clinical requirements.
CSHM intends to appeal the notice of exclusion and file a request for hearing with the Department Appeals Board. During the appeals process, the exclusion will be stayed and we will continue to provide business, administrative and support services to 53 associated dental centers in 19 states and the District of Columbia, pursuant to our management services agreements. The legal process will take an indeterminate period of time. In the interim, CSHM will continue to perform normal operations and will continue to provide our internal and external constituents with up-to-date information. Should you have questions regarding this matter, please contact a member of our communications team at Lovell Communications:
- Paula Lovell: 615-297-7766 / lovell@lovell.com
- Rosemary Plorin: 615-297-7766 / rosemary@lovell.com
- Perry Hall: 615-297-7766 / perry@lovell.com
- Link to original media release - http://smallsmiles.com/PressReleases/MediaResponseStatement_LV_20140312.pdf
- Saved copy-
http://www.scribd.com/doc/212174183/CSHM-Small-Smiles-Dental-Media-Statement-03-11-2014
***********************
- Link to original payor memo -
http://smallsmiles.com/PressReleases/CSHM_Payor_Memo_20140312.pdf - Saved copy of payor memo -
http://www.scribd.com/doc/212466391/David-R-Wilson-President-CEO-of-CSHM-Small-Smiles-Dental-Payor-Letter-03-12-2014
Thursday, March 13, 2014
Positive proof of no compliance at CSHM–Small Smiles
You have to check out CSHM-Small Smiles “Quality and Compliance” webpage. Past the list of the overseers, you will find a link that says“For more information, please visit: www.smallsmiles.com/compliance.
Go ahead, click it.
NBC — Firm That Manages Dental Clinics for Kids Excluded From Medicaid
By Talesha Reynolds
MARCH 12, 2014 - A company that manages a chain of dental clinics once accused of subjecting children to painful and unnecessary procedures and bilking the government for millions of dollars has been notified it will no longer be eligible for reimbursement from federal health care programs like Medicaid, its principal source of revenue.
The company, CSHM, manages 53 clinics nationwide, most of which operate under the name Small Smiles. The clinics treat mostly low-income children in areas where access to dental care is limited.
The Office of the Inspector General of the Department Health and Human Services sent a letter to CSHM on Friday citing multiple breaches to a compliance agreement, which mandates quality of care measures. The breaches included failing to report incidents involving patients at Small Smiles clinics in Tulsa, Okla., and Mattapan, Mass.
The OIG declined to provide further detail on the specific breaches that led to the exclusion.
Sen. Chuck Grassley, R-Iowa, who last year published a report on corporate dental management companies along with former Sen. Max Baucus, D-Mont., said Monday that the CSHM exclusion notice “will protect both taxpayers and vulnerable children receiving dental care in the Medicaid program.”
Related:
Dental chain accused of hurting kids, bilking taxpayers December 11, 2012