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On November 20, 2020, in a joint effort, the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) and the Centers for Medicare & Medicaid Services (“CMS”) issued final rules to revise and modernize the Physician Self-Referral Law (“Stark Law”), Anti-Kickback Statute (“AKS”) and Civil Monetary Penalties Law (“CMP”). CMS’ final rule […]

This blog serves as an update to our previous blog, entitled “Update to New York OMIG and DRA Certification Requirements,” posted on November 10, 2020. The previous blog may be accessed here. By way of brief background, the New York State Department of Health (NYSDOH) announced in its October 2020 Medicaid Update (available here) that […]

On June 17, 2019, the Centers for Medicare & Medicaid Services (CMS) announced a settlement option for certain IRF appeals pending at any of the four fee-for-service Medicare administrative appeals levels: the Medicare Administrative Contractor (MAC), qualified independent contractor (QIC), the Office of Medicare Hearings and Appeals (OMHA) Administrative Law Judge (ALJ), and/or the Medicare […]

In a speech at the American Bar Association’s Physician Legal Issues Conference on June 11, 2105, a representative from the Office of Inspector General (OIG) noted that the OIG is currently hiring attorneys to gear up to pursue claims against physicians under the OIG’s administrative penalty authorities. This means that the OIG will not wait […]

On June 9, 2015, the Office of Inspector General (OIG) issued a Fraud Alert titled “Physician Compensation Arrangements May Result in Significant Liability,” which is available here. In the Fraud Alert, the OIG warns physicians of the dangers of entering into compensation arrangements with health care entities, such as medical directorships or office staff arrangements, […]

On June 9, 2015, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a fraud alert warning physicians of significant liability for entering into medical directorships that are non-compliant with the federal Anti-Kickback Statute (AKS). Medical directorships must reflect fair market value for bona fide services that the physicians actually […]

As expected, the U.S. Department of Health and Human Services (“HHS“) officially set the ICD-10 compliance date for October 1, 2015. Previously, providers and payors had until October 1, 2014 to transition from the ICD-9 to the ICD-10 Procedure Coding System. However, the Protecting Access to Medicare Act of 2014 prevents HHS from adopting ICD-10 […]

In the recently released Federal Register, The Office of Inspector General (OIG) informed the public that that it intends to update the Provider Self-Disclosure Protocol (the Protocol) and is soliciting input. The Protocol, which was first introduced in 1998, is the process that health care providers can take in order to disclose potential fraud involving […]

The House and Senate passed a revised version of H.R. 3630, the Middle Class Tax Relief and Job Creation Act of 2012, which guarantees that physicians will avoid a 27.4 percent cut in Medicare reimbursement for an additional ten months. Instead of the schedule cuts which were expected to be enacted on March 1, physician […]

On February 7, 2012, The Centers for Medicare and Medicaid Services (CMS) released a Request for Comments regarding two demonstration programs it intends to conduct. The first, the Recovery Audit Prepayment Review Demonstration, will allow CMS and its agents to request additional documentation, including medical records, to support submitted claims. In Chapter 3 of the […]

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