Recently in Health Law Category

April 9, 2014

NYS Final Budget Out of Network Reform

The final budget bill was recently passed in New York State containing several provisions for Out-of-Network ("OON") reforms. The major changes related to OON reform include: 1) transparency provisions requiring the reestablishment of "usual, customary and reasonable" or "UCR" charges to determine reimbursement rates; 2) adding protections allowing patients to go OON for specialty care; 3) requiring insurers to "make available" OON options reimbursed at 80% UCR; 4) creating a new independent dispute resolution ("IDR") process to resolve disputed claims between insurers and providers; and 5) formation of an OON reimbursement rate workgroup to analyze the effect of the reforms. These reforms not only ensure greater patient choice and access to care, but help protect physician practices that have, for decades, struggled to be adequately reimbursed by insurers for legitimate services provided to patients OON. The following is a brief synopsis of each reform:

Reestablishment of UCR:
Beginning in 2015, insurers must be transparent in regards to their rates of reimbursement for services as a percentage of UCR. UCR will be reestablished and defined as "the 80th percentile of all charges for the particular service in the same or similar specialty and same geographic area as reported in the benchmarking database maintained by FAIR Health."

Increasing OON Access and Coverage: Protections have been added, allowing patients to seek OON physicians when their network does not have providers with proper training and expertise for their treatment. Patients will have the option to purchase UCR-based OON products and may request such options from companies that issue comprehensive policies in the group market that cover OON. Such companies must "make available" at least one option for at least 80% of UCR. If no OON coverage option is available in a particular region in New York State, the Superintendent of the Department of Financial Services ("Superintendent") may require insurers selling in the group market of that region to "make available" a similar option.

Independent Dispute Resolution Process (IDR):
Greater consumer protections will be enacted against "surprise medical bills." An additional "hold harmless" protection will be in place for consumers who receive care from an OON provider as a result of an emergency situation or through no fault of their own and without notice. Instead, insurers and providers will be allowed to utilize the new IDR process to dispute claims. Rulings through IDR are required to be issued within 30 days of receipt of the request for dispute, ensuring expeditious resolution for providers. To determine a reasonable fee, the IDR entity will consider factors including:

• The physician's usual charges for the same or similar services;
• Fees paid by the insurer to reimburse similarly qualified OON physicians for the same services;
• Level of training, education and experience of the physician;
• Circumstances and complexity of the particular case, including time and place of the service; individual patient characteristics; and
• The usual and customary cost of the service.

OON Reimbursement Rate Workgroup:
A workgroup will be formed, aimed at improving access and adequacy of OON services and coverage options. Consisting of two physicians, two insurance representatives, and three consumers and co-chaired by the Superintendent and the Commission of the Department of Health, the workgroup will produce a findings report by January 1, 2016. The workgroup will review and make recommendations regarding the following:

• Current OON reimbursement rates used by insurers and FAIR Health's rate methodology;
• Availability and adequacy of the OON coverage in individual and small group markets in every region; and
• Prevalence of coverage based on UCR or other reimbursement methodologies, such as Medicare.

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April 8, 2014

CMS Establishing a Hospice Quality Reporting Program

The Centers for Medicare & Medicaid Services ("CMS") announced in a Federal Register notice that it is creating a new data-collection program for hospice quality reporting called the Hospice Item Set ("HIS") System.

The HIS System, which is mandated under Section 3004(c) of the Patient Protection and Affordable Care Act of 2010 ("ACA"), establishes a new system of records for patient-level data collection. CMS states that the data will confirm whether the appropriate assessments were made, and whether inquiries and concerns were addressed, for each hospice patient. The data CMS plans to collect for each patient includes:

• Pain,
• Respiratory status,
• Medications,
• Patient preferences, and
• Beliefs and values.

Under the program, which hospices must begin using by July 1, 2014, hospices will submit information to the system at the time of admission (and at the time of discharge if a patient does not die).

CMS plans to use strict time limits regarding submission of the information. Hospices must complete admission forms within 14 days of entry, and where applicable, complete discharge forms within 7 days of discharge. The forms must be submitted to the CMS system within 30 days of admission or discharge. Failure to timely report the information could result in cuts to CMS reimbursements.

Notably, under the new information system, information will be collected on all hospice patients, not just patients who are Medicare beneficiaries.

The hospice quality reporting program announcement can be viewed here.

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April 8, 2014

Medicare to Release Physician Payment Information

On April 2, 2014, the Centers for Medicare & Medicaid Services ("CMS") announced its intent to publish data on its payments to individual physicians. Beginning on April 9, 2014, CMS plans to release information regarding the charges for medical services and procedures furnished by physicians and other health care professionals.

CMS stated that the data on the types of medical services and procedures furnished by physicians will be organized by National Provider Identifier ("NPI"), Healthcare Common Procedure Coding System ("HCPCS") code, and the place of service (i.e., whether the services were furnished in a facility or office setting). The data to be released include:

• The number of services performed at each NPI/HCPCS code/place of service;
• The average submitted charges and standard deviation in submitted charges;
• The average allowed amount and standard deviation in allowed amount;
• The average Medicare payment and standard deviation in Medicare payment; and
• A count of unique beneficiaries treated.

CMS claims that the information would give the public a better picture of how physicians practice in the Medicare program. CMS also stated that the information will assist the public in understanding Medicare fraud, waste, and abuse. In a letter to the American Medical Association ("AMA"), CMS stated that the increased transparency will help patients make informed decisions about the care they receive.

However, many assert that the information could easily be misinterpreted. For example, Medicare pays different rates for services in different cities and regions, which may not be clear to those lay persons viewing the information. Doctors may also charge higher rates for complex patients, or when there are extenuating circumstances. Some doctors also see a higher number of patients with Medicare, necessarily resulting in higher overall billings to the program.

In a statement, AMA president Ardis Dee Hoven, M.D., said: "The AMA is concerned that CMS' broad approach to releasing physician payment data will mislead the public into making inappropriate and potentially harmful treatment decisions and will result in unwarranted bias against physicians that can destroy careers." To help curb misleading information, Dr. Hoven stated that "the AMA strongly recommended that physicians be permitted to review and correct their information prior to the data release."

CMS' letter to the AMA announcing the decision can be viewed here.

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April 7, 2014

The HLP's Clinton Mikel, Esq. to Present CLE Webinar

In need of Ethics Credits? ABA members can get them for free by attending, "You Mean HIPAA Applies to Lawyers? Keeping Data Safe, Clients Happy and Your License Secure", with The HLP's, Clinton Mikel, Esq., as a Speaker/Moderator, April 21, 2014.

February 26, 2014

Florida MRI Clinic Sues Insurer for Improper Denial of PIP Benefits

It is customary for insurers to deny claims submitted by no-fault providers, and providers, in turn, commonly challenge these denials. Conversely, it is anomalous for a no-fault provider to initiate a (putative) class action suit in response to an insurer's payment denials. Yet, in a recently filed action, an aggrieved provider did just that.

Pan Am Diagnostic Services, Inc. ("Pan Am"), an MRI clinic based in Florida, filed a putative class action on February 19th in Florida court against Equity Insurance Co. ("Equity") for wrongly denying PIP benefits. Pan Am claims that the insurer improperly used payments made to nonmedical providers as a justification for denying payment on valid claims by medical providers.

Under Florida Vehicle No-Fault Law, automobile operators must have insurance that includes at least $10,000 combined medical expense and disability coverage, also known as personal-injury-protection or "PIP." Insurers must pay 80 percent of medically necessary expenses resulting from an accident.

Payments made to nonmedical providers should not be part of the calculations in determining whether a policyholder's PIP medical benefits coverage has been exhausted. Such a scheme makes it appear that the policyholder has already depleted their PIP benefits and legitimate claims by medical providers are unjustly denied.

In a 2012 incident cited by Pan Am, Equity paid only one third of a claim submitted for medical services provided to an Equity policyholder. Equity claimed that the policyholder had exhausted his PIP benefits from a prior treatment by another provider. The prior settlement, however, included several nonmedical costs in addition to compensation for medical care. Pan Am alleges that the policyholder's medical expense limit had not been met and Equity made deceptive settlement payments to falsely imply depletion of the $10,000 coverage.

Such aggregation of prior non-medical costs by insurers can result in acute financial detriment to medical providers whose claims are then improperly denied after they have already provided legitimate medical care. Pan Am is seeking injunctive relief and compensatory damages from Equity.

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February 21, 2014

Recovery Audit (RAC) Program Changes Announced

The Centers for Medicare & Medicaid Services ("CMS") announced changes to the Medicare Fee-For-Service Recovery Audit Program in a posting on the website February 18, 2014. According to CMS, the changes will go into effect after the new Recovery Audit Program contracts are awarded.

The announcement includes changes to the contingency fees paid to Recovery Audit Contractors ("RACs") and limits on additional documentation requests ("ADRs") issued by RACs.

Under the program changes, Recovery Auditors will not receive a contingency payment until a reconsideration decision at the second level of appeal by a Qualified Independent Contractor ("QIC"). This change, however, is unlikely to satisfy providers, who must wait an average of 16 months after the QIC decision to have their case heard by an Administrative Law Judge. According to the American Hospital Association, in more than 70 percent of inpatient denials by RACs, ALJs rule in favor of providers. The vast majority of hospitals will thus continue to wait many months to recoup improperly denied Medicare payments even under the CMS revised rules.
In addition, CMS announced that it will revise ADR limits based on the type of claim at issue, and that ADR limits will be further adjusted based on a provider's denial rates. According to CMS, providers that have lower denial rates will have lower ADR limits, while providers with high denial rates will have high ADR limits.

CMS is also revising its rules regarding the discussion period after a RAC payment denial. Currently, a RAC is required to stop discussion with a provider after the provider files an appeal. Under the new rules, a RAC must wait 30 days to allow discussion. RACs must also confirm receipt of a discussion request within 3 days under the program changes.

CMS is currently in the process of awarding auditor contracts. The transition from the current RACs to the new RACs will be proceeded by a cease of auditing activity. CMS states that the pause in activity is necessary so that it can refine and improve the Medicare Recovery Audit Program. After the new RAC contracts are awarded, CMS states that audits will resume and claims during the transition period will be reviewed.

The RAC Program Improvements announcement can be viewed here.

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February 19, 2014

Feds Crack Down on HITECH Act EHR Program Fraud

Federal authorities are cracking down on abuse of the HITECH Act's Meaningful Use financial incentive program as evidenced by the recent indictment of Joe White, former CEO of Shelby Regional Medical Center ("Shelby Regional") in Tyler, Texas. A federal grand jury indicted White on charges of making false statements to the Centers for Medicare and Medicaid Services ("CMS") and aggravated identity theft.

The American Recovery and Reinvestment Act of 2009 established incentive payments under the Medicare and Medicaid programs for eligible professionals ("EPs") and eligible hospitals who adopt, implement, upgrade or demonstrate meaningful use of Certified Electronic Health Record Technology ("EHR").

CMS is making available up to $27 billion in EHR incentive payments, or as much as $44,000 (through Medicare) or $63,750 (through Medicaid) per EP. The incentive programs were created to promote the use of health information technology in order to improve quality, maintain privacy and security of patient health information, and to reduce the cost of healthcare in the United States.

According to White's indictment, it is alleged that he falsely attested to CMS that Shelby Regional met the Meaningful Use requirements for the 2012 fiscal year. However, Shelby Regional relied on paper records throughout the fiscal year and only minimally used electronic health records. Allegedly, to give the false appearance that the hospital was actually using certified EHR software, White directed its software vendor and hospital employees to manually input data from paper records into the EHR software, often times months after the patient was discharged and after the end of the fiscal year. Additionally, the indictment further alleges that White falsely attested to the hospital's meaningful use by using another person's name and information without that individual's consent or authorization. As a result of the false attestation, CMS paid Shelby Regional over $785,000.

If convicted, White faces up to 5 years in federal prison for making a false statement and up to 2 years in federal prison for aggravated identity theft.

In light of this recent indictment, it is imperative that eligible hospitals and EPs participating in the EHR Incentive Program are in compliance with the HIPAA Security Rule and all other Meaningful Use attestation requirements. It is a specific requirement of the Incentive Program for eligible hospitals and EPs to conduct a security risk analysis of the practice to identify potential risks and vulnerabilities related to the confidentiality, integrity, and availability of electronic protected health information. It is important to note, when attesting to meaningful use, all providers may be subject to a meaningful use audit, since Congress has identified this program as a risk area for abuse.

The Health Law Partners has experience with respect to all HIPAA related matters and representing EPs, hospitals, and providers in Meaningful Use audits.

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February 19, 2014

CMS to Release a Comparative Billing Report on PAP Devices and Accessories

On January 16, 2014, the Centers for Medicare & Medicaid Services ("CMS") announced that it will release a national provider Comparative Billing Report ("CBR") addressing Positive Airway Pressure ("PAP") Devices and Accessories.

CMS is using CBRs as a tool to educate providers about applicable Medicare billing rules in furtherance of its goal to improve the level of care provided to Medicare patients.

The CBRs will be produced by eGlobalTech and will contain actual data-driven tables and graphs with an explanation of findings that compare providers' billing and payment patterns to those of their peers location in the same state and across the country.

CBRs are not available to anyone but the provider who receives them. Additionally, the reports do not include patient or case-specific data, but rather only contain summary billing information as a method of ensuring privacy.

CMS has identified specific provider types to receive CBRs due to certain billing vulnerabilities. To date, these providers include: chiropractors, ambulances, hospices, podiatrists, physical therapists, evaluation and management services, sleep studies, home health services, and spinal orthotics.

CBR data analysis utilizes the same data-mining tools used by Medicare contractors to identify candidates for audit. Therefore, it is likely that any vulnerabilities identified in the CBR may eventually be identified by CMS contractors who select providers for audit.

It is imperative that providers who receive a CBR evaluate the information contained in the report and consider conducting an internal compliance audit to determine whether any differences in billing patterns are attributable to billing errors or other reasons (e.g., serving different patient populations). Additionally, providers should consider contacting a healthcare attorney to evaluate the CBR and develop an appropriate compliance program to reduce the risk of audit going forward.

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January 28, 2014

Medicare Enforcement Increased Significantly in 2013

The U.S. Justice Department's Medicare Fraud Strike Force set record numbers for health care prosecutions throughout the Country in Fiscal Year (FY) 2013.

The Medicare Fraud Strike Force is a coordinated team of investigators and prosecutors from the Justice Department, the U.S. Department of Health and Human Services and the FBI who, under the supervision of the U.S. Attorney's Offices and Justice Department's Criminal Division, analyze Medicare claims data for unusual billing patterns in specific geographic areas. The Medicare Fraud Strike Force currently operates out of 9 cities: Baton Rouge, La.; Brooklyn, N.Y.; Chicago; Dallas; Detroit; Houston; Los Angeles; Miami and Tampa, Fla. Since its inception in March 2007, its operations have resulted in more than 1,700 defendants being charged.

In FY 2013 alone, the Medicare Fraud Strike Force filed 137 cases charging 345 individuals. Moreover, there were 234 guilty pleas and 46 jury trial convictions. In addition, the defendants who were charged and sentenced in FY 2013 faced an average of 52 months in prison compared to an average of 47 months for those sentenced since 2007.

In light of a recent statistic from the OIG that for every $1 spent in fraud enforcement nearly $8 is received, rest assured such enforcement will continue and likely increase for the foreseeable future.

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January 20, 2014

Article on Medicare Audit Program's Burden on Hospitals Features HLP Attorneys Abby Pendleton and Jessica Gustafson

An article in Hospitals & Health Networks ("H&HN"), the flagship publication of the American Hospital Association, quoted HLP attorneys Abby Pendleton and Jessica Gustafson on the effects of Medicare audits on hospitals.

The article, published on January 14, 2014, discusses the overwhelming burden on hospitals created by the Medicare audit program and recovery audit contractors ("RACs"). Specifically, the article notes that although hospitals are successful in over 70 percent of RAC claim denial appeals, the cost of these appeals is steep. Hospitals are often forced to devote considerable resources to dedicated RAC response teams so that they can respond to RAC record requests and meet the stringent filing deadlines.

The high success rate of hospitals on appeal is an indication that RACs are not applying the Medicare standards correctly in their audits. As Pendleton points out in the article, RACs earn a contingency fee of 9 to 12.5 percent on claim denials, and are misapplying standards and looking for any way to deny claims. Pendleton also notes that many small hospitals are not able to afford the resources required to comply with the often onerous record requests caused by RAC audits, and cannot appeal the Medicare payment denials.

The article also discusses the Medicare Audit Improvement Act of 2013, which seeks to reform the Medicare audit system. Some reforms include limiting the number of medical records that RACs can request, and penalizing RACs when hospitals are successful on appeal. But, as Gustafson states in the article, RAC audits are likely here to stay. Because RACs collect so much money from hospitals, it is unlikely that legislation will seriously limit RAC powers. But hospitals can put pressure on regulators, who can do a better job on ensuring that RACs apply the correct standards in their audits.

The article, "Whacked by RAC," is available at

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January 17, 2014

Meaningful Use Attestation Deadline Quickly Approaching

February 28, 2014 marks the deadline for eligible professionals ("EPs") to register and attest to demonstrating meaningful use for the 2013 Medicare Electronic Health Records ("EHR") Incentive Program. EPs must successfully attest by 11:59 pm ET on February 28 to receive incentive payment for 2013 participation.

The Medicare EHR Incentive Program provides incentive payments to eligible professionals, hospitals, and critical access hospitals that demonstrate meaningful use of certified EHR technology. EPs have the opportunity to receive up to $44,000 over five years under the EHR Incentive Program and a percentage of incentive payments.

Payment adjustments for EPs will be applied beginning January 1, 2015, to Medicare participants that have not successfully demonstrated meaningful use. The adjustment is determined by the EP's reporting period in a prior year.

EPs participating in the Medicaid EHR incentive program should refer to their state deadlines for attestation information.

It is imperative that EPs participating in the EHR Incentive Program are in compliance with the HIPAA Security Rule and all other meaningful use attestation requirements. It is a specific requirement of the Incentive Program for EPs to conduct a security risk analysis of the practice to identify potential risks and vulnerabilities related to the confidentiality, integrity, and availability of electronic protected health information. When attesting to meaningful use, all providers may be subject to a meaningful use audit, since Congress has identified this program as a risk area for abuse.

The Health Law Partners has experience with respect to all HIPAA related matters and representing EPs and providers in Meaningful Use audits.

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January 17, 2014

In Contravention of Federal Law, CMS Delays Assignment of New Requests for Administrative Law Judge Hearings

In a memorandum to Office of Medicare Hearings and Appeals ("OMHA") applicants, the Centers for Medicare and Medicaid Services ("CMS") announced that it will temporarily suspend the assignment of new requests for Administrative Law Judge ("ALJ") hearings for two years. CMS stated in the memo that the reason for the temporary suspension is the increasing backlog of ALJ hearing requests.

According to CMS, OMHA's claims and entitlement workload grew by 184% from 2010 to 2013, while adjudicative resources stayed relatively constant. As a result, the OMHA backlog of claims for services and entitlement appeals that are currently assigned has grown to over 357,000. Meanwhile, new requests for ALJ hearings average over 15,000 per week.

The average wait time for an ALJ hearing is already 16 months, according to CMS. It estimates that general assignment will not resume for 24 months as OMHA works through the current backlog, and even after that, post-assignment wait times will continue to exceed six months. Hospitals thus face the prospect of waiting at least 30 months to recoup disputed funds.

To the great detriment of providers/appellants, CMS' latest action is directly in contravention of federal law and regulations requiring DHHS ALJs to issue decisions within 90 days of receipt of the hearing request. Hospitals around the country are outraged at the back-log and particularly outraged at this new CMS announcement. Notably, the American Hospital Association ("AHA") has written a letter to CMS Administrator Marilyn Tavenner, contending that CMS' delay violates the law. The AHA states that the 30-month delay directly violates the Medicare statute, which requires ALJs to issue a decision within 90 days of receipt of a request for hearing.

The AHA correctly points out that excessive and inappropriate denials of Medicare services by Recovery Audit Contractors ("RACs") directly contributes to the ALJ hearing request backlog. The AHA states that, in more than 70 percent of inpatient denials by RACs, ALJs rule in favor of the hospital. This suggests that the majority of inpatient claims denied by RACs are actually appropriate, necessary claims that are supported by clinical guidelines.

Instead of suspending assignment of current appeals, the AHA urges Tavenner to suspend all RAC audits until the backlog has been processed. The AHA also requests that CMS only recover funds from RAC denials after an ALJ decides the case, rather than after the second (QIC) level of appeal. This would allow hospitals to retain payment for disputed claims while the backlog of ALJ hearings is addressed. The AHA also urges that the 90-day statutory timeframe be enforced by CMS through entries of default in favor of the provider in cases that exceed the time period.

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January 16, 2014

Dermatology Practice Pays $150,000 to Settle Allegations of HIPAA Violations

On December 26, 2013, the Department of Health and Human Services ("HHS") and Adult & Pediatric Dermatology, P.C. ("APDerm") agreed to settle potential violations of the HIPAA Privacy, Security, and Breach Notification Rules for $150,000. In addition the $150,00 settlement, APDerm will also be required to implement a corrective action plan to correct deficiencies in its HIPAA compliance program.

This marks the first settlement with a covered entity under which the HHS Office of Civil Rights ("OCR") specifically cited the practice for not having policies and procedures in place to address the breach notification provisions of the Health Information Technology for Economic and Clinical Health Act ("HITECH Act").

The OCR initiated an investigation of APDerm after receiving a report than an unencrypted thumb drive containing electronic protected health information ("ePHI") of approximately 2,200 patients was stolen from a staff member's vehicle. The thumb drive was never recovered. After the close of the investigation, OCR determined that APDerm failed to conduct an accurate and thorough analysis of the potential risks and vulnerabilities to the confidentiality of the ePHI as a part of its security management process. Additionally, OCR found that APDerm failed to fully comply with the Breach Notification Rule by not having written policies and procedures in place and by failing to properly train its workforce members.

This settlement highlights the significance of conducting routine risk and vulnerability assessments, having adequate written policies in place, and conducting workforce training on HIPAA privacy and security policies. It is imperative that all covered entities affirmatively review the mandatory requirements under the HIPAA Omnibus Rule.

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January 16, 2014

CMS to Begin Unveiling Individual Physician Payment Information

On January 14, 2014, the Centers for Medicare & Medicaid Services ("CMS") announced a new policy regarding requests made under the Freedom of Information Act ("FOIA") on amounts paid to individual physicians under the Medicare program. This notice reverses more than 30 years of prior policy. CMS will now make case-by-case determinations as to whether exemption 6 of FOIA applies to a given request for such information. The new policy will take effect 60 days after publication in the Federal Register, which is scheduled Friday, January 17, 2014.

This announcement flows from a May 2013 ruling by U.S. District Judge Marcia Morales Howard in Jacksonville, Fla. where she lifted a 1979 injunction that barred the release of Medicare payment data holding that physicians' privacy concerns no longer outweighed the public interest in releasing the data.

Following the court's ruling, CMS sought public comment on its proposed policies with respect to the disclosure of individual physician payment information. Physician groups expressed caution in Medicare releasing such information, saying it could lead to "misleading conclusions and unintended consequences."

CMS notes that it recognizes these valid concerns raised by stakeholders. In turn, CMS will consider the importance of protecting physician's privacy and ensure the accuracy of any data that is released as well as appropriate protections to limit potential misuse of the information. However, CMS believes that replacing the prior policy is "the best next step for the agency."

Under the new policy, CMS will make case-by-case determinations as to whether exemption 6 of FOIA applies to a given request for information regarding individual physician payment information. Exemption 6 requires CMS to weigh the balance between the privacy interest of individual physicians and the public interest in the disclosure of such information. The outcome will depend on the facts and circumstances of each individual case.

This policy change is in accordance with CMS' ongoing effort to make information more available to the public. In 2010, HHS launched the Health Data Initiative to promote transparent, innovative, and safe data use. Since then, the agency has released an "unprecedented amount" of aggregated data with much of it available at

In light of this change, physicians need to be aware of the potential consequences associated with the possible disclosure of such information. Specifically, this policy opens the risk for government investigation, the use of information by competitors, and the perception of impropriety.

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January 16, 2014

CMS Issues Enrollment Updates to Chapter 15 of the Program Integrity Manual

On December 27, 2013, the Centers for Medicare & Medicaid Services ("CMS") issued revisions to Chapter 15 of the Medicare Program Integrity Manual.
The key clarifications/updates of interest to providers include:

• Instructions for processing disclosures of final adverse actions reported by providers and suppliers or law enforcement agencies;

• New instructions for the maintenance of information for all "Contact Persons" listed in Section 13 of Form CMS-855 until the provider or supplier provides written instructions for removing the contact person's information from the Provider Enrollment, Chain, and Ownership System; and

• Additional clarification for determining whether a change of ownership ("CHOW") has occurred after a stock transfer.

The updates will be implemented on January 28, 2014.

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