Articles Posted in Uncategorized

On February 18, 2010, the Centers for Medicare and Medicaid Services released a transmittal addressing home health agencies (“HHAs”) that have deactivated billing privileges as well as conditions on HHAs and changes in ownership (the “Revised HHA Policy”). The Revised HHA Policy affords relief to those HHAs that submitted change-of-ownership (“CHOW”) applications prior to January […]

In the past month, Michigan has experienced a great deal of Medicare and Medicaid news. On February 11, Governor Jennifer Granholm announced that in her proposed 2011 budget, she would continue the 8% Medicaid cuts to hospitals, physicians, long-term care, and mental health providers. Further, her proposed budget also reintroduced the 3% physician tax that […]

The federal estate tax has been repealed for 2010 only and will be re-imposed in 2011. Congressional efforts to cancel the repeal failed late last year. Now that Congress is back in session, it is likely Congress will again try to cancel the repeal retroactive to January 1, 2010. Even if the repeal is canceled […]

At the request of certain members of Congress, the Federal Trade Commission (FTC) has extended the enforcement date of the Red Flags Rule to June 1, 2010. Originally intended to be enforced on November 1, 2008, the FTC has delayed the enforcement date a number of times to ensure that those affected entities have adequate […]

On September 22, 2009, the U.S. Senate’s Chairman’s Mark released a draft legislation regarding the future of healthcare in the United States. Some notable points include: – Limiting physician referrals only to permit hospitals that meet certain exemption requirements, which would be more stringent than the current Medicare requirements; – Establishing a process to update […]

The current legislative initiatives to restrict (or eliminate) the In-Office Ancillary Services Exception (the “IOASE”) under Stark is, by no means, a new phenomenon. Rather, over the years, CMS has received a substantial number of comments from interested groups whose economic interests are adversely affected by the IOASE. In fact, the amendments to the Anti-Markup […]