Articles Posted in Compliance

On May 28, the Centers for Medicare and Medicaid Services (CMS) issued Transmittal 128, which clarifies CMS policies regarding physician supervision of diagnostic and therapeutic services provided to hospital outpatients. The transmittal, effective on July 1, 2010, updates the Hospital Outpatient Prospective Payment System (OPPS). In the transmittal, CMS specifies that “[d]irect supervision is the […]

In a long-anticipated maneuver, the American Medical Association (“AMA”), American Osteopathic Association (“AOA”) and the Medical Society of the District of Columbia (“MSDC”) filed a lawsuit last week seeking to block the Federal Trade Commission (“FTC”) from requiring physician practices to implement its “Red Flag” identity theft safeguards. In an ongoing saga that HLP has […]

The Office of the Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”) issued a report this month showing that program safeguard contractors (“PSCs”) have not resulted in significant recoveries to the Medicare program. PSCs are intended to detect and deter fraud and abuse in Medicare, by conducting investigations and, at issue, […]

On April 29, 2010, the U.S. Sentencing Commission issued new amendments to the standards for, and criteria included in, an “Effective Compliance and Ethics Program” in the Federal Sentencing Guidelines. These amendments have important implications for all corporate health care providers. For more information on corporate governance and effective compliance programs, please contact Abby Pendleton, […]

The recently passed health care reform bill–known more technically as the Patient Protection and Affordable Care Act–contains a provision bound to increase enforcement regimes for health care providers. For instance, at Section 6401(a)(7), the Act creates mandatory compliance programs for providers enrolled in Medicare and Medicaid. The Secretary of Health and Human Services is tasked […]