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CMS Proposes to Extend Virtual Direct Supervision

On July 10, the Centers for Medicare & Medicaid Services (CMS) proposed to extend virtual direct supervision—i.e., the ability to provide direct supervision through real-time, audio-visual technology (rather than in-person...more

CMS Announces New MSSP Model Aimed at Improving Primary Care

The Centers for Medicare & Medicaid Services (CMS) recently announced the ACO Primary Care Flex Model (ACO PC Flex Model or Model), a new voluntary payment model for primary care furnished through low-revenue Accountable Care...more

CMS Extends Virtual Direct Supervision Through 2024

On November 2, the Centers for Medicare & Medicaid Services (CMS) extended virtual direct supervision—i.e., the ability to provide direct supervision through real-time, audio-visual technology (rather than in-person presence)...more

CMS Publishes New Data on Self-Referral Disclosure Protocol Settlements

The Centers for Medicare & Medicaid Services (CMS) recently published updated data regarding settlements made under the Voluntary Self-Referral Disclosure Protocol (SRDP), an important mechanism through which providers may...more

While Remote Supervision Remains Available for Direct Supervision, Be Mindful of the Other “Incident to” Requirements

With the May 11, 2023 expiration of the federal public health emergency (PHE) for COVID-19, many operational flexibilities healthcare providers used during the PHE will now sunset. Some flexibilities end immediately while...more

OIG Offers Guidance for ASCs When Physician-Investors Fail the One-Third Income Test

Nearly 25 years ago, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) created a regulatory safe harbor to the federal Anti-Kickback Statute (AKS) for physician investment in...more

HHS-OIG Year in Review - 2022

The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) continues to offer valuable insights to the healthcare industry as to how best to approach increasingly complex healthcare fraud...more

CMS Tweaks Voluntary Self-Referral Disclosure Protocol, Adds New Form for Group Practice Disclosures

On January 23, the Centers for Medicare & Medicaid Services (CMS) released revisions to its Voluntary Self-Referral Disclosure Protocol (SRDP), an important mechanism through which providers may disclose actual or potential...more

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