Recent Medicare regulations regarding ownership changes for HHAs have been the source of controversy and confusion. After numerous attempts by HLP founding partner Robert Iwrey, Esq. to obtain clarification regarding enforcement of these regs, Rob was pleased to receive an email this morning from Frank Whelan, a CMS adminstrator with…
On February 22, The Health Law Partners, P.C. (“The HLP”) posted a blog urging our clients and friends to help prevent a proposed 21% reduction in Medicare reimbursement. On February 28, the short-term Medicare physician payment freeze expired, triggering the 21% reduction in Medicare reimbursement. Congress is expected to vote…
Following the leads of a number of other States, including New York, Michigan Governor Jennifer Granholm has issued an Executive Order creating an independent Office of Health Services Inspector General (the “OHSIG”). According to the Executive Order, OHSIG, which will be organized as an independent and autonomous entity within the…
Unverified accounts have it that enforcement of the “business associate” provisions of the HITECH Act, which was set to commence on February 17, 2010, is being delayed. The business associate provisions require business associates of covered entities to also implement the HIPAA Security Rule, and portions of the HIPAA Privacy…
As a service to our clients and friends in NY, we are reproducing the notice circulated by the Medical Society of the State of New York urging all interested constituents take action to prevent the proposed 21% reduction in Medicare physician reimbursement. “On February 28, the two month extender of…
The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) requires the Secretary to designate organizations to accredit suppliers, including but not limited to physicians, non-physician practitioners, and Independent Diagnostic Testing Facilities, that furnish the technical component of advanced diagnostic imaging services. Advanced diagnostic imaging services include diagnostic magnetic…
CMS rescinded a change order affecting the use of place of service (“POS”) codes used for the interpretation of diagnostic tests. Originally issued on December 11, 2009, the rescinded Change Request (“CR”) led to significant confusion about the POS for reporting the reading of diagnostic tests. MLN Matters 6375, which…
The home health world has been turned upside down. As many are aware, new regulations have been implemented that affect ownership changes for home health agencies (“HHAs”). On January 21, 2010, CMS published a “Medicare Learning Network Provider Inquiry Assistance.” This publication clearly states that any “ownership change” within 36…
The American Recovery and Reinvestment Act establishes an incentive program that provides incentive payments to eligible physicians (EP) and eligible hospitals for meaningfully using electronic health records (EHR). While many specialists are learning the conditions under which they can capitalize on these incentive payments, anesthesiologists will learn that they do…
Generally, Durable Medical Equipment (“DME”) suppliers are statutorily prohibited from telemarketing Medicare beneficiaries regarding furnishing a covered item. There are three exceptions to this rule: (a) the beneficiary has given written consent to be contacted by the supplier; (b) the contact is regarding a covered item that the supplier has…