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Stark In-Office Ancillary Services Exception Disclosure Requirements Effective January 1, 2011

Effective January 1, 2011, the new Stark In-Office Ancillary Services Exception (the “IOASE”) provisions will require physicians or group practices relying upon the IOASE (collectively, “Physician Practices”) to furnish the following notice/disclosure to patients receiving MRI, CT, and PET (as identified on the Stark CPT/HCPCS Code list): • Written notice…

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Legislation Introduced to Extend Medicare Reimbursement Rates

Representatives Dingell (D-Mich.), Pete Stark (D-Calif.), and other representatives have introduced legislation to extend the current physician Medicare reimbursement rates for 13 months as well as to provide a 1% update for this year and next year. We will continue to keep our readers apprised of any future developments. For…

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Hospice Recertification Requirements Under CMS 2011 Home Health Prospective Payment System

In its November 3, 2010 release of the final 2011 Home Health Prospective Payment System (“2011 HHPPS”), the Centers for Medicare and Medicaid Services (“CMS”) updated its hospice recertification requirement. Beginning January 1, 2011, the Affordable Care Act requires that physicians and non-physician practitioners attest to a beneficiary’s recertification for…

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CMS Released 2011 Final Home Health Prospective Payment System

On November 3, 2010, the Centers for Medicare and Medicaid Service (“CMS”) posted its final 2011 Home Health Prospective Payment System (“2011 HHPPS” or the “Final Rule”). According to CMS, “this final rule reflects CMS’ ongoing efforts to improve quality of care provided by home health agencies to Medicare beneficiaries.…

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RAC Frequently Asked Questions Updated

Following The HLP’s submission of numerous written inquiries and phone calls to representatives of CMS, National Government Services, Inc. (“NGS”) (the Medicare Affiliated Contractor), and CGI (the Medicare RAC for Region B), on November 8, 2010, CMS published a response to Frequently Asked Questions related to RAC reviews of Periodic…

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Medicaid RAC Proposed Rule Issued

On November 10, 2010, the Centers for Medicare & Medicaid Services (“CMS”) published its much-anticipated Proposed Rule regarding the Medicaid Recovery Audit Contractor (“RAC”) program. Section 6411 of the Patient Protection and Affordable Care Act (“Affordable Care Act”) requires each State to establish a Medicaid RAC program similar to the…

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Key Updates from the CMS 2011 Final Physician Fee Schedule

CMS’s 2011 Final Physician Fee Schedule (the “Fee Schedule”) provides for over 2000 pages of new rules and regulations pertaining to physician reimbursement under Medicare for 2011. With the passing of the Patient Protection and Affordable Care Act (“PPACA”) and the Healthcare and Education Reconciliation Act (collectively referred to as…

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OIG Issues Additional Advisory Opinions on Managing Hospital Sleep Lab

Following upon the heels of September’s first-ever Advisory Opinion on sleep testing, the Office of Inspector General today issued the second and third installments of what appears to be the OIG’s Sleep Opinion Trilogy. These new opinions generally follow the facts of the first opinion – a third party management…

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CMS 2011 Final Physician Fee Schedule: Interim Final Values For Sleep Codes

CMS published its interim final values for sleep testing yesterday, November 2, 2010, as part of Medicare’s Final Part B Physician Fee Schedule for 2011. Although the sleep code values are to be effective January 1, 2011, CMS is offering the public the opportunity to comment on these new sleep…