The Office of Inspector General (“OIG”) has posted its Health Care Fraud Prevention and Enforcement Action Team (“HEAT”) compliance training resources on its website wherein it provides videos and audio podcasts regarding a number of topics, including: An overview of the OIG Overviews of the healthcare fraud and abuse laws; Exclusion from Medicare; Compliance programs; […]
In a December 13, 2011 press release, the Department of Health and Human Services (“HHS”) announced that the Department of Justice (“DOJ”) has recovered over $5.6 billion in total fraud in 2011, an increase of over 167% since 2008. Of this $5.6 billion recovered in 2011, over $2.9 billion (over 51%) recovered was due to […]
On December 7, 2011, the Office of Inspector General (“OIG”) posted a favorable Advisory Opinion 11-18 pertaining to Requestor’s online service that would facilitate the exchange of information between healthcare practitioners, providers and suppliers (“Proposed Arrangement”). Requestor, a publicly traded company, currently provides web-based services that help physicians “achieve faster reimbursement from payors, reduce error […]
The Medicare and Medicaid Electronic Health Record (“EHR”) Programs incentivize the meaningful use of certified EHR technology to achieve health and efficiency goals. Eligible professionals and hospitals that meet certain requirements using certified EHR technology (i.e., satisfy certain “meaningful use” criteria) will be eligible for incentive payments of up to $44,000 over a five-year participation […]
In the November 28, 2011 Federal Register, the Centers for Medicare and Medicaid Services (“CMS”) retracted its requirement that physicians or non-physician practitioners (“NPPs”) sign requisitions for clinical laboratory tests paid under the Clinical Laboratory Fee Schedule (“CLFS”). When it was first enacted ten years ago, in 2001, CMS revised 42 CFR 410.32(d)(2) to require […]
Today, CMS held its Open Door Forum related to the CMS A/B Rebilling Demonstration. General information related to the CMS call is available at http://go.cms.gov/cert-demos. This website includes a Frequently Asked Question document, slides related to the call, and the enrollment application. CMS outlines the process for the rebilling demonstration as follows: Once a provider […]
In Advisory Opinion 11-17, the Office of Inspector General (“OIG”) reviewed an arrangement in which a laboratory services management company (“Requestor”) “proposes to provide allergy testing and immunotherapy laboratory services and related items to primary care physicians and physician practices (“Physicians”) within the Physicians’ medical offices. Specifically, Requestor would enter into exclusive contracts with the […]
The Obama Administration announced that Centers for Medicare and Medicaid Services (“CMS”) Administrator, Donald Berwick, MD, would be stepping down on December 2. His replacement, Marilyn Tavenner, served as Virginia’s Secretary of Health and Human Services from 2006 to 2010 and then served as the CMS Principal Deputy Administrator and Chief Operating Officer. Continue Reading […]
According to a press release, the Department of Health and Human Services (“HHS”) announced that it will be awarding $9 million from the Centers for Medicare and Medicaid Services (“CMS”) to Senior Medicare Patrol (“SMP”) programs across the country tasked at fighting Medicare fraud. SMP is operated by the Administration on Aging in close partnership […]
On November 17, 2011, the Centers for Medicare and Medicaid Services (“CMS”) announced that it will delay enforcement action until March 31, 2012 for those Health Information Portability and Accountability Act (“HIPAA”) covered entities that are not in compliance with the ASC X12 Version 5010, NCPDP Telecom D.0 and NCPDP Medicaid Subrogation 3.0 standards. CMS […]
Health Law Attorney Blog