One of HLP’s founding partners, Adrienne Dresevic, Esq., who specializes in Stark and fraud & abuse analysis, published a new article in the latest issue of the RBMA Bulletin, a publication of the Radiology Business Management Association. Adrienne’s article, entitled “Key Regulations Impacting Marketing: Entertainment and Gifts,” explains the regulatory limitations placed on health care […]
On February 22, The Health Law Partners, P.C. (“The HLP”) posted a blog urging our clients and friends to help prevent a proposed 21% reduction in Medicare reimbursement. On February 28, the short-term Medicare physician payment freeze expired, triggering the 21% reduction in Medicare reimbursement. Congress is expected to vote within the next several days […]
Following the leads of a number of other States, including New York, Michigan Governor Jennifer Granholm has issued an Executive Order creating an independent Office of Health Services Inspector General (the “OHSIG”). According to the Executive Order, OHSIG, which will be organized as an independent and autonomous entity within the Department of Community Health, is […]
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 Office of Inspector General (OIG) released a report discussing some of its recent findings regarding the Recovery Audit Contractor (RAC) 3-year demonstration program. The report revealed that between March 2005 and March 2008, the RACs “referred two cases of potential fraud to the Centers for Medicare & Medicaid Services (CMS). However, CMS reported that […]
Unverified accounts have it that enforcement of the “business associate” provisions of the HITECH Act, which was set to commence on February 17, 2010, is being delayed. The business associate provisions require business associates of covered entities to also implement the HIPAA Security Rule, and portions of the HIPAA Privacy Rule, and also requires that […]
As a service to our clients and friends in NY, we are reproducing the notice circulated by the Medical Society of the State of New York urging all interested constituents take action to prevent the proposed 21% reduction in Medicare physician reimbursement. “On February 28, the two month extender of the current Medicare > conversion […]
A legal ruling finding that the Red Flag Rules promulgated by the Federal Trade Commission (“FTC”) do not apply to the profession of law has raised new hope that physicians may find a similar exemption. In a final rule published in 2007 under the Fair and Accurate Credit Transaction Act of 2003, the FTC issued […]
A Florida Appeals Court upheld a ruling last month that a hospital-based but non-contracted provider may not balance bill patients for amounts unpaid by the patients’ HMO, when the HMO has accepted liability. The text of the ruling can be found here. In this case, the patients, each a subscriber to one HMO, received pre-authorization […]
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