The Office of Inspector General (OIG) recently issued a favorable advisory opinion (Advisory Opinion) to a university health system (Requestor) regarding two arrangements: (1) a proposal to waive cost-sharing obligations of...more
On December 7, 2016, the Department of Health and Human Services Office of Inspector General (OIG) issued a long-awaited final rule (Final Rule) that expands the safe harbor regulations under the Anti-Kickback Statute (AKS)...more
12/20/2016
/ Ambulance Providers ,
Anti-Kickback Statute ,
Civil Monetary Penalty ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
OIG ,
Remuneration ,
Rural Areas ,
Safe Harbors
On October 14, 2016, the Centers for Medicare and Medicaid Services (CMS) released a final rule with comment period (Final Rule) implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The Final Rule...more
10/28/2016
/ Alternative Payment Models (APM) ,
CEHRT ,
Centers for Medicare & Medicaid Services (CMS) ,
Health Care Providers ,
Healthcare ,
Medicare ,
Medicare Access and CHIP Reauthorization (MACRA) ,
MIPS ,
Physician Medicare Reimbursements ,
Physicians ,
PQRS ,
Quality Payment Program (QPP) ,
Rural Health Care Providers ,
Value-Based Payments
On September 27, 2016, the U.S. Court of Appeals for the Third Circuit handed the Federal Trade Commission (FTC) a significant antitrust victory by granting its request for a preliminary injunction to stay the pending merger...more
DOJ, NY AG REACH SETTLEMENT WITH HOSPITALS IN LANDMARK 60 - DAY RULE CASE -
On August 24, 2016, the U.S. attorney for the Southern District of New York and the New York State attorney general announced a $2.95 million...more
9/7/2016
/ 60-Day Rule ,
Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Medicare Part A ,
Medicare Part B ,
Overpayment ,
Overpayment Recovery Time Limits ,
Physician Assistants ,
Settlement ,
Vaccinations
The Centers for Medicare & Medicaid Services (CMS) recently issued a final rule (Final Rule) that implements the Comprehensive Care for Joint Replacement model (CJR Model), a new bundled payment program covering certain...more
CHANGES TO STARK LAW, NEW ADVANCE CARE PAYMENTS INCLUDED IN 2016 PHYSICIAN
FEE SCHEDULE -
The Centers for Medicare & Medicaid Services (CMS) recently published a final rule (Final Rule) regarding physician payment...more
On October 29, 2015, the Centers for Medicare & Medicaid Services and the Office of Inspector General of the Department of Health & Human Services (jointly, the “Agencies”) issued a final rule (Final Rule) regarding waivers...more
On October 16, 2015, the Centers for Medicare & Medicaid Services (CMS) published a final rule (Final Rule) that streamlines Stage 2 and finalizes Stage 3 of the Medicare and Medicaid electronichealth record (EHR) Incentive...more
11/4/2015
/ CEHRT ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
EHR ,
Electronic Health Record Incentives ,
Final Rules ,
Health Care Providers ,
Healthcare ,
Meaningful Use ,
Medicaid ,
Medicare ,
Reporting Requirements
The Health Resources and Services Administration (HRSA) recently issued proposed omnibus guidance (Omnibus Guidance) interpreting various provisions of the 340B Drug Pricing Program (340B Program). The 340B Program allows...more
10/8/2015
/ 60-Day Rule ,
Centers for Medicare & Medicaid Services (CMS) ,
Covered Entities ,
Department of Justice (DOJ) ,
Drug Pricing ,
False Claims Act (FCA) ,
Fee-for-Service ,
GPOs ,
Healthcare ,
HIV ,
HRSA ,
Managed Care Contracts ,
Medicaid ,
Medicare ,
Overpayment Recovery Time Limits ,
Patients ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Section 340B ,
Whistleblowers
The U.S. Department of Justice (DOJ) recently announced that KMART Corp. (Kmart) has paid $1.4 million to settle a qui tam lawsuit brought by a former Kmart pharmacist under the False Claims Act (FCA). The lawsuit alleged...more
9/9/2015
/ Anti-Kickback Statute ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Generic Drugs ,
Healthcare ,
HEAT ,
Kickbacks ,
Kmart ,
Medicare ,
Pharmacies ,
Prescription Drugs
On August 21, 2015, the United States Court of Appeals for the District of Columbia Circuit (DC Circuit) reinstated Department of Labor (DOL) regulations that require home care agencies and other third-party employers of...more
On August 3, 2015, the United States District Court in the Southern District of New York issued a long-awaited opinion and order rejecting a motion to dismiss filed by the defendants in U.S. ex rel. Kane v. Continuum Health...more
8/21/2015
/ 60-Day Rule ,
Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Medicare Part A ,
Medicare Part B ,
Overpayment ,
Overpayment Recovery Time Limits ,
Whistleblowers
The Office of the Inspector General (OIG) recently issued a favorable advisory opinion (Advisory Opinion) to a nonprofit health system (System) and a nonprofit psychiatric hospital (Center) regarding a proposal whereby the...more
8/18/2015
/ Advance Directives ,
Affordable Care Act ,
Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Employees ,
Fair Market Value ,
FQHC ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Non-Profit Hospitals ,
OIG ,
Physician Fee Schedule ,
Physicians ,
Rural Health Care Providers ,
Stark Law ,
Timeshare
On June 29 and 30, 2015, the Connecticut General Assembly conducted a special legislative session following the close of the 2015 regular session. Among other things, the General Assembly passed a bill to implement the state...more
8/13/2015
/ Audits ,
Certificate of Need ,
DSS ,
FQHC ,
Health Care Providers ,
Healthcare ,
HIV ,
Home Healthcare Workers ,
Hospitals ,
Medicaid ,
Medicaid Reimbursements ,
Medical Reimbursement ,
Municipalities ,
Nurses ,
Nursing Homes ,
Pay-for-Performance ,
Personal Property ,
Prescription Drugs ,
Property Tax ,
Public Health ,
Reporting Requirements ,
Screening Procedures ,
Tax Rates
President Obama recently signed into law Public Law No. 114-10, the “Medicare Access and CHIP Reauthorization Act of 2015” (P.L. 114-10), which overhauls Medicare physician reimbursements by eliminating the use of the...more
On May 26, 2015, Connecticut Governor Dannel P. Malloy signed into law Public Act 15-11 (PA 15-11), “An Act Concerning Persons Who Decontaminate Reusable Medical Instruments or Devices.” This new legislation requires central...more
On May 11, 2015, Connecticut Governor Dannel P. Malloy signed into law Public Act 15-4, “An Act Concerning Reporting of Payments by Manufacturers to Independently-Practicing Advanced Practice Registered Nurses” (P.A. 15-4)....more
The Centers for Medicare and Medicaid Services (CMS) recently published a proposed rule (Proposed Rule) implementing Stage 3 of the Medicare and Medicaid electronic health record (EHR) Incentive Programs (Meaningful Use...more
On January 23, 2015, the United States Department of Labor (DOL) filed a notice of appeal with the United States Court of Appeals for the District of Columbia (District Court) challenging two rulings in the case of Home Care...more
2/23/2015
/ Appeals ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Fair Labor Standards Act (FLSA) ,
Fee-for-Service ,
Final Rules ,
Healthcare ,
Home Health Agencies ,
Home Health Care ,
Home Healthcare Workers ,
Meaningful Use ,
Medicare ,
Quality of Care Standards ,
Wage and Hour
In This Issue:
- Connecticut Supreme Court Rules State Does Not Recognize Mature Minor Doctrine
- OIG Issues Advisory Opinion Permitting Copayment Assistance
- CMS Announces Recovery Audit Program...more
The Centers for Medicare and Medicaid Services (CMS) recently published a proposed rule (Proposed Rule) that would revise regulations governing accountable care organizations (ACOs) that participate in the Medicare Shared...more
In This Issue:
- Connecticut Supreme Court: HIPAA Does Not Preempt Negligence Claims
- CMS Removes Continuing Education Exemption to Physician Payments Sunshine Act
- Federal Government and New York...more
11/24/2014
/ Centers for Medicare & Medicaid Services (CMS) ,
Continuing Medical Education ,
False Claims Act (FCA) ,
Health Care Providers ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Medicaid ,
Negligence ,
PHI ,
Sunshine Act
In This Issue:
- OIG Releases Proposed Rule Revising the Anti-Kickback Statute Safe Harbors and Civil Monetary Penalty Rules
..AKS Safe Harbors
..Revisions to the Civil Monetary Penalty...more
In This Issue:
- CMS Updates Guidance on Hospital Governing Body and Medical Staff Conditions of Participation (CoPs)
- DOL Announces Delay of Home Care Minimum Wage Enforcement
- OIG Releases Special...more