On November 8, 2021, the Office of Inspector General (“OIG”) issued multiple updates to the Health Care Fraud Self-Disclosure Protocol (“SDP”), incorporating legal changes made since the previous SDP revision in 2013. The OIG’s updated SDP may be accessed here. Below is an overview of the updates. By way of brief background, the SDP provides […]

Recently, the U.S. Dept. of Health and Human Services (“HHS”), Dept. of Labor, Dept. of Treasury, and the Office of Personal Management jointly issued an interim final rule regarding surprise medical billing. The interim final rule, entitled “Requirements Related to Surprise Billing: Part 1” (the “Rule”) may be accessed here, and will go into effect […]

President Biden recently signed the Act to Prevent Across-the-Board Direct Spending Cuts, and for Other Purposes (the “Act”) (available here) into law. The Act extends the temporary suspension of certain mandatory Medicare FFS claim payment reductions until December 31, 2021. By way of background, the Budget Control Act of 2011 required mandatory across-the-board reductions to […]

On April 13, 2021, the American Bar Association (ABA) Health Law Section Nominating Committee announced its slate of Officers and Council members for FY 2022.  The HLP is honored that two of our founding shareholders are included on this slate. The HLP congratulates Adrienne Dresevic on her nomination to serve as Vice Chair of the […]

On January 15, 2021, the Department of Health and Human Services (“HHS”) issued updated guidance on reporting requirements related to use of Provider Relief Fund (“PRF”) monies.  HHS will be issuing further updates, which will impact how providers are required to report and whether providers will be allowed to retain all of the PRF monies […]

The Centers for Medicaid & Medicare Services (CMS) recently released the 2021 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Final Rule, which may be accessed here. Significantly, the Final Rule contains policy changes by CMS that are intended to provide Medicare patients and their physicians greater choices in the outpatient setting at […]

The Centers for Medicaid & Medicare Services (CMS) recently released the 2021 Physician Fee Schedule (PFS) Final Rule. The PFS Final Rule is scheduled to be published on December 28, 2020, but an unpublished version may be accessed here. CMS has also issued a fact sheet, which overviews the changes made by the 2021 PFS […]

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 […]

Michigan recently enacted legislation intended to protect consumers from surprise medical billing. The legislation amends Michigan’s public health code (PHC) by adding Article 18, which establishes disclosure requirements and limitations on payments for out-of-network providers (i.e., providers that do not participate in a patient’s health benefit plan) in certain circumstances. The law was enacted primarily […]

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 […]

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