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Search OptionsHealth CareOffice of Inspector General Clarifies Online Digital Platforms and Marketing Practices for Physicians
The Health and Human Services Office of Inspector General (“OIG”) recently published an Advisory Opinion (“AO 19-04”) concerning the use of online platforms for finding and booking physician appointments and physician marketing. While the OIG determined that the platform and payment structure… OCR Holds True to Right of Access Initiative with First Enforcement Action
Earlier this year, the Office of Civil Rights (“OCR”) at the U.S. Department of Health and Human Services (“HHS”) announced its Right of Access Initiative. The Right of Access Initiative promises to vigorously enforce the rights of patients to receive copies of their medical records without facing… Judge Strikes Down Payment Cuts For Outpatient Department Evaluation and Management Services
In a decision dated September 17, 2019, a Federal judge invalidated a 2018 Centers for Medicare and Medicaid Services (“CMS”) regulation that attempted to align Medicare Part B payments for Evaluation & Management (“E&M”) services in hospital outpatient departments (“OPD”) with the lower rates paid… INSPECT Requirements for Prescriber Delegates
The Indiana Scheduled Prescription Collection and Tracking (“INSPECT”) program is an online tool that maintains a clearinghouse of patient information for health care professionals. The INSPECT database limits access to certain individuals and entities including the following: health care… CMS and OIG Online Sources Provide Important Updates Regarding Corporate Compliance
Health care, and its many statutory, regulatory and industry “yardsticks” are ever-changing and require regular attention. In order to stay close to the action, particularly with respect to matters concerning corporate compliance, there are at least three online sources to consider. The first is… CMS Warns “Beware of the Company You Keep” In New Sanctions Rule
In a new rule effective November 4, 2019, the Centers for Medicare & Medicaid Services (“CMS”) expanded Federal and State authority to punish providers with a troubled history or for affiliating with “bad actors” (the “New Rule”). In announcing the New Rule, CMS Administrator Seema Verma… CMS Proposes New Rules Aimed at Reshaping Medicare Payment Policies
On July 29th, CMS jointly released its Proposed Rules for the 2020 Medicare Physician Fee Schedule and 2020 Hospital Outpatient Prospective Payment System that would update Medicare payment policies aimed at increasing price transparency, improving quality, and reducing burdens on providers. Some… CMS Issues Final Rule Easing Restrictions On Arbitration Agreements In Long Term Care Setting
The Centers for Medicare & Medicaid Services (CMS) published a Final Rule on July 18, 2019 that repealed a prior rule prohibiting Long-Term Care (LTC) facilities from using pre-dispute, binding arbitration agreements. LTC facilities that choose to utilize arbitration agreements must adhere to… Compliance Update: RCRA 'Subpart P' and the New Hazardous Waste Pharmaceutical Rules
Health care facilities will need to comply with new regulations governing the management and disposal of Hazardous Waste Pharmaceuticals (“HWPs”). The Environmental Protection Agency (“EPA”) has promulgated new rules to be codified at 40 C.F.R. Part 266, Subpart P of the implementing regulations of… CMS Issues Long Awaited Clarification on Application of EMTALA to Psychiatric Hospitals
On July 2, 2019, the Centers for Medicare and Medicaid Services (“CMS”) issued a letter to State Survey Agency Directors with Frequently Asked Questions on the application of the Emergency Medical Treatment and Labor Act (“EMTALA”) to Psychiatric Hospitals (the “FAQ”). This is the second time this… Department of Justice Publishes New Guidance for Evaluating Corporate Compliance Programs
On April 30, 2019, the United States Department of Justice (“DOJ”) published new recent guidance for corporate compliance programs, entitled “Evaluation of Corporate Compliance Programs.” Such publications are particularly helpful as they provide guidance for white-collar prosecutors on the… Say What You Mean and Mean What You Say - Especially to the Feds
The recent settlement between Coffey Health System in Kansas and the U.S. government is a cautionary tale to other healthcare providers: false attestations related to government incentive programs could lead to False Claims Act liability. Coffey Health System operates a 25-bed critical access… |
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