On August 3, 2020, two issues were approved for review and posted on the Centers for Medicare & Medicaid Services (CMS) Recovery Audit program website: 0184 – Total Hip Arthroplasty: Medical Necessity and Documentation Requirements, and 0185 – Total Knee Arthroplasty: Medical Necessity and Documentation Requirements. In particular, the approved issues involve whether the documentation […]
The Office of Medicare Hearings and Appeals (OMHA) has recently opened the Settlement Conference Facilitation (SCF) to the appellant community. The SCF is an alternative dispute resolution (ADR) process meant to bring certain providers and the Centers for Medicare & Medicaid Services (CMS) together to discuss mutually agreeable resolutions for Medicare Part A and B […]
The Centers for Medicare and Medicaid Services (CMS) has issued two new proposed rules. First, CMS has issued a proposed rule for the 2021 Medicare Physician Fee Schedule (PFS Proposed Rule). The rule will be published on August 17, 2020. You can access the unpublished version here. Second, CMS issued a proposed rule for the […]
Recently, the Small Business Administration (SBA) issued guidance regarding loan forgiveness for the Paycheck Protection Program (PPP). In its guidance, the SBA details the PPP loan forgiveness process and reiterates certain rules and requirements for PPP loan forgiveness. We discussed the PPP loan forgiveness rules and requirements in a prior post, available here. Below is […]
The Department of Health and Human Services (HHS) has issued new FAQs regarding how Provider Relief Fund (PRF) payments may be spent and when recipient-providers must report their use of funds. Under the Terms/Conditions that apply to recipients of PRF funds, each provider is required to have a written policy or written procedures to govern […]
This blog is intended to supplement our prior guidance regarding Paycheck Protection Program (PPP) loan forgiveness, found here. On June 3, 2020, following the House of Representatives’ approval, the U.S. Senate passed bill H.R. 7010 (i.e., the Paycheck Protection Program Flexibility Act of 2020 (the “Bill”)). Subsequently, President Trump signed the Bill into law on […]
On May 21, 2020, the U.S. Small Business Administration (SBA), in consultation with the Department of Treasury, issued two Interim Final Rules pertaining to loan forgiveness under the Paycheck Protection Program (PPP). The first Interim Final Rule, entitled SBA Loan Review Procedures and Related Borrower and Lender Responsibilities, provides rules regarding procedures for borrowers and […]
On March 24, 2020, the U.S. District Court for the District of Connecticut granted a class of Medicare beneficiaries the right to challenge their designation in hospitals as outpatients receiving observation services rather than as inpatients. In the case, Alexander v. Azar, the court ruled that the Department of Health and Human Services (HHS) violated […]
On May 21, 2020, Michigan Governor Whitmer issued Executive Order (EO) 2020-96, which permits outpatient healthcare facilities (e.g., primary care physician offices and dental offices) to re-open and perform non-essential medical and dental procedures. EO 2020-96, in part, rescinds prior EO 2020-17 as of May 28, 2020 at 11:59 p.m., which had required physicians and […]
In a continued effort to combat the nation’s opioid crisis, the Department of Health and Human Services Office of the Inspector General (OIG) has recently developed two toolkits that analyze prescription data to identify patients at risk of opioid misuse or overdose. The toolkits are available in three programming languages – one toolkit includes SAS […]
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