The New York State Office of the Medicaid Inspector General (OMIG) issued guidance on its requirements for Medicaid compliance, effective October 26, 2016. This Compliance Program Review Guidance (“Guidance”) will assist the Medicaid Required Provider (“Required Provider”) community in developing and implementing compliance programs that meet the requirements of Social Services Law Section 363-d (“SSL […]
Following a lengthy dispute process and significant delays, on October 31, 2016, CMS awarded new Medicare Fee-for-Service RAC contracts to the following contractors: Region 1 – Performant Recovery, Inc. Region 2 – Cotiviti, LLC Continue Reading →
Private practitioners who wish to remain independent, but who are struggling to survive because of decreased third-party reimbursements and increasing overhead expenses, are being aggressively courted by various business entities that will analyze-often for free-whether the concierge model of medicine, or some variation thereof, might add significant profitability to the practice’s bottom line. The earliest […]
Medicare has developed a new incentive payment framework (“MACRA”) which is intended to fundamentally change the way in which the Federal Government evaluates and pays for the healthcare services that are provided to Medicare beneficiaries. It is designed to move us away from a volume-based “fee-for-service” reimbursement system to one which emphasizes the quality of […]
On July 28th, 2016, researchers from Harvard, in conjunction with researchers from several hospitals, published a study in the BMJ which found that the implementation of new electronic health records (EHRs) systems does not have material repercussions on patient care in hospitals. The study observed 17 hospitals implementing new EHRs, along with a control group […]
On July 29, 2016, the Centers for Medicare & Medicaid Services (“CMS”) announced that it is expanding statewide (and extending for an additional six (6) months), the temporary enrollment moratoria on new Medicare Part B home health agencies (“HHAs”) in Florida, Texas, Illinois, and Michigan. The statewide expansion also applies to Medicaid and Children’s Health […]
The United States Department of Health and Human Services has new actions planned to address the opioid crisis. The buprenorphine rule has been finalized, which allows physicians who have waivers to prescribe buprenorphine products (e.g., Suboxone) for up to 100 patients for 1 year or more to obtain a waiver to treat up to 275 […]
New rules published on June 30th, 2016 in the Federal Register could dramatically change the regulatory enforcement landscape for healthcare providers, with fraud penalties nearly doubling under the False Claims Act and the Anti-Kickback Act. The False Claims Act (which in pertinent part imposes penalties on healthcare providers for submitting false claims to a government […]
On Thursday, the U.S. Supreme Court issued a decision that recognizes implied certification as a viable theory under which to pursue False Claims Act cases against healthcare providers. Implied certification can impose liability if a contractor has engaged in a lie by omission, for instance, failing to disclose its noncompliance. In the case, Universal Health […]
The HHS Office for Civil Rights (“OCR”) has begun issuing notices for Phase 2 HIPAA Audits applicable to covered entities and their business associates. In Phase 2, OCR will review the policies and procedures adopted and employed by covered entities and their business associates to satisfy standards and implementation specifications of the Privacy, Security, and […]
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