As the “Red Flag Rules” enforcement date of May 1, 2009 quickly-approaches, health care providers need to get prepared. The Red Flag Rules require financial institutions and “creditors” to develop and implement identity theft prevention programs that provide for identification, detection, and response to patterns, practices or specific activities (known…
According to the Office of Inspector General (“OIG”) 2009 Work Plan, “incident to” services continue to be an area of scrutiny. The OIG is currently reviewing this billing area and expects to issue a report of its findings in 2009. In summary, in order to bill “incident to” services, the…
The Health Information Technology for Economic and Clinical Health Act (“HITECH Act” or the “Act”) included in the “Stimulus Bill” significantly expands HIPAA privacy and security provisions. Health care organizations and providers may be interested in some of the critical aspects of the HIPAA privacy and security portions as follows:…
New York Medicaid Inspector General Mandates Compliance Programs Although compliance programs have traditionally been viewed as voluntary, on January 14, 2009, the Office of Medicaid Inspector General issued proposed regulations mandating the establishment and maintenance of compliance programs for many Medicaid participating providers. In addition to applying to certain providers…