Effective April 1, 2011, hospice and home health providers will be required to comply with the face-to-face rule for purposes of verification of a patient’s eligibility for Medicare home health services and of recertification for Medicare hospice services. Enforcement of this requirement was delayed from January 1, 2011, in order…
Health Law Attorney Blog
Alan G. Gilchrist, Esq. Joins The HLP to Lead Civil False Claims and Criminal Defense Practice Group
The Health Law Partners, P.C. (“The HLP”) is pleased to announce that Alan G. Gilchrist, Esq., has joined the firm as a partner. The HLP is excited to welcome Gilchrist to our growing team of lawyers specializing in health care law. Gilchrist will chair the firm’s Civil False Claims and…
The Highly Anticipated ACO Guidance Has Been Issued!
On Thursday, March 31, 2011, the Centers for Medicare & Medicaid Services (“CMS”) provided the health care community with some much needed guidance by publishing its Proposed Rule regarding the Medicare Shared Savings Program (the “Shared Savings Program”) and its Accountable Care Organizations (“ACOs”). There is a sixty (60) day…
ACO Proposed Regulations Issued
Today, CMS issued the long-awaited proposed regulations for accountable care organizations (ACOs). The regulations may be found here. For more information, please contact the Health Law Partners at (248) 996-8510, (212) 734-0128 or (770) 804-6475 or visit the ACO specialty page on the HLP website.
OIG Views Favorably Complimentary Transportation Services in Adv. Op. 11-02
In the Office of Inspector General’s (OIG) Advisory Opinion 11-02, the OIG examined a proposed arrangement in which the Requestor–a non-profit, tax-exempt corporation that operates an outpatient acute care hospital–would provide complimentary transportation services to patients and their families at physicians’ offices located on, or contiguous to, the Requestor’s campus…
5th and 9th Circuits Rule the HHS Hospice Cap Invalid
Following a December challenge in the Northern District of Texas, the ninth circuit (Los Angeles Haven Hospice, Inc. v. Sebelius, No. 09-56391 (9th Cir. Mar. 15, 2011)) and the fifth circuit (Lion Health Servs. V. Sebelius, No. 10-10414 (5th Cir. Mar. 11, 2011)) have both ruled that the hospice cap…
Advocacy Groups Pushing to Delay Face-to-Face Rule
Section 6407 of the Patient Protection and Affordable Care Act requires a face-to-face encounter for home health and hospice patients to qualify for Medicare coverage. On March 12, 13 prominent medical societies and advocacy groups sent a letter to the Centers for Medicare and Medicaid Services (CMS) requesting a postponement…
Holder and Sebelius in Detroit, MI
On March 15, 2011, US Attorney General Eric Holder, Secretary of Health and Human Services (HHS) Kathleen Sebelius and Inspector General Daniel Levinson visited Detroit to participate in the fifth regional health care fraud prevention summit. These summits bring together a wide array of federal, state and local partners, beneficiaries,…
Faculty Physicians Experiencing Increased Salaries
According to an article in Modern Physician, most faculty physicians experienced an increase in their salaries from 2009 to 2010. Based on a report from the Medical Group Management Association (MGMA), “the median compensation for primary-care faculty physicians was $163,704, up 3.47% from $158,218 in 2009, and the median pay…
ACO Regulations May Finally Be Near
Since the signing of the Patient Protection and Affordable Care Act (PPACA) last year, there has been considerable attention and interest within the industry towards accountable care organizations (ACOs). Accompanying this focus has been a series of questions regarding the compositional requirements, as well as the operational and structural opportunities…