CMS Releases Guidance for MACs on 100% Prepayment and Random Medical Reviews
On October 18th, CMS issued Transmittal 489 [PDF], providing Medicare Administrative Contractors (MACs) with instructions on 100 percent prepayment and random reviews. The guidance, effective November...
View ArticleCMS Clarifies Broad Scope of Hospices' Payment Responsibility for Part D Drugs
In a December 6, 2013 memorandum [PDF] to all Medicare hospice providers and Part D plan sponsors, CMS expressed concern that drugs covered under the Part A hospice benefit are being billed to Part D...
View ArticleOIG's 2014 Work Plan: A Roadmap to Key OIG Fraud and Abuse Priorities
The Department of Health and Human Services, Office of the Inspector General (OIG) released its Fiscal Year (FY) 2014 Work Plan on January 31, 2014. While the OIG usually releases its work plan in...
View ArticleProgram Integrity Priorities Revealed in FY 2015 HHS Budget
On March 14, 2014, President Obama unveiled his Administration’s proposed fiscal year 2015 budget for the Department of Health and Human Services (HHS). In total, the Administration is seeking $77.1...
View ArticleMedicare Bad Debt: Courts Again Uphold HHS's Stringent "Must Bill" Policy...
On March 25, 2014, the United States District Court for the District of Maine upheld the decision of the Department of Health and Human Services (HHS) to withhold from Maine Medical Center (MMC),...
View ArticleOIG Proposes Updates to Exclusion and CMP Authority
The Department of Health and Human Services, Office of Inspector General (OIG) recently issued a pair of proposed regulations to update its exclusion and civil monetary penalty (CMP) authority. The...
View ArticleProposed Hospice Rule Focuses on Unbundling of Services
On May 8, CMS released a proposed rule in the Federal Register providing for a payment increase of 1.3 percent for fiscal year (FY) 2015. Among other provisions, CMS’s proposed rule offers hospice...
View ArticleDiscount Drug Program Passes OIG Scrutiny
On July 28th, 2014, the Department of Health and Human Services, Office of Inspector General (OIG) released favorable advisory opinion 14-05, concluding that a pharmaceutical manufacturer’s...
View ArticleOverview of the FY 2015 IRF Final Rule
On August 6th, the Centers for Medicare and Medicaid (CMS) published an Inpatient Rehabilitation Facility (IRF) final rule [PDF] in the Federal Register outlining (1) new Medicare payment policies and...
View ArticleCMS Releases New, Proposed Home Health Conditions of Participation
CMS published a proposed rule on Thursday, October 9th, 2014, updating the Home Health Agency (HHA) Conditions of Participation (CoPs). The proposed rule represents the first update to the HHA CoPs...
View ArticleCMS Releases Final Physician Fee Schedule Rule: Key Payment and Policy...
On October 31, 2014, CMS released the final Medicare physician fee schedule (PFS) rule. The new payment policies and rates set forth in the PFS final rule will go into effect on or after January 1,...
View ArticleACO Fraud and Abuse Waivers Extended Through November 2, 2015
On October 17, 2014 the Centers for Medicare and Medicaid (CMS) and Office of Inspector General (OIG) within the Department of Health and Human Services published a continuation notice in the Federal...
View ArticleOIG Again Approves Medicap Insurer's Contract with Preferred Hospital Network
On October 21, 2014, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 14-10, approving a Medigap insurer’s proposed contract with a preferred...
View ArticleHighlights of the 2015 Home Health Prospective Payment Rule
On November 6, 2014, CMS published its final Medicare home health prospective payment system (HH PPS) rule for calendar year (CY) 2015. As highlighted below, notable changes in the HH PPS final rule...
View Article"Next Generation" ACO Model Announced by CMS
In a March 10, 2015 press release, CMS announced a new addition to its existing Accountable Care Model (ACO) portfolio: Next Generation ACOs. As stated by CMS in its press release, this new ACO model...
View ArticleMedigap Insurer's Contract with Preferred Hospital Network Approved (Yet Again)
On April 22, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-05 [PDF], approving a Medigap insurer’s proposed contract with a preferred...
View ArticleProposed 2016 Physician Fee Schedule Would Impact Medicare Shared Savings...
The proposed Physician Fee Schedule for 2016 [PDF] contains several provisions that are likely to have an impact on the Medicare Shared Savings Program (MSSP). These provisions focus in large part on...
View ArticleKey Ingredients of CMS' Proposed Comprehensive Care for Joint Replacement Model
On July 14, 2015, CMS released a proposed rule regarding a new, alternative payment model: the Comprehensive Care for Joint Replacement (CCJR) program. Modeled in large part on the Bundled Payments for...
View ArticleHome Health, CY 2016 Proposed Rule: Emphasis on Value-Based Purchasing
On July 10, 2015, CMS published the calendar year (CY) 2016 home health prospective payment system (PPS) proposed rule [PDF]. While the proposed rule updates and revises certain payment rates and...
View ArticleOIG Approves Limited, Free Drug Program
On August 12, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-11, approving two pharmaceutical manufacturers’ free starter drug program....
View ArticleCMS Proposes Significant Revisions to Hospital Discharge Planning Process:...
On November 3, 2015, CMS released a proposed rule revising existing discharge planning requirements for hospitals, critical access hospitals (CAHs) and home health agencies (HHA). CMS stated impetus...
View ArticleStark Updates Included in Final 2016 Physician Fee Schedule
With the final Medicare physician fee schedule (PFS) for 2016, the Centers for Medicare and Medicaid Services (CMS) has made a series of updates to the Stark physician self-referral regulations. The...
View ArticleCharity's Patient Assistance Program Passes OIG Muster in Advisory Opinion 15-17
On December 28, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued OIG Advisory Opinion 15-17, approving a charity’s proposal to unveil a new patient assistance...
View ArticleOIG Approves Free Transportation and Lodging for Certain, Low-Income Pregnant...
On March 1, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-02 [PDF], approving an academic medical center's (AMC's) provision of free...
View ArticleAll Right Stop, Collaborate and Listen! CMS Is Back with Its Brand New...
Understandably, there is anticipation surrounding the April 1st start date for CMS’s newest bundled payment program, the Comprehensive Care for Joint Replacement (CJR) program. As participant hospitals...
View ArticleCMS's Proposed IPPS and LTCH FY 2017 Rule: Key Takeaways
On April 18, 2016, CMS released its proposed rule addressing new payment rates and policies under both the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective...
View ArticleCMS Announces Plans to Streamline the Stark Self-Referral Disclosure Protocol
On May 6, 2016, CMS published a notice (Notice), required under the Paperwork Reduction Act (PRA), seeking public comment on its plans to revise the information collected under the Medicare...
View ArticleSenate Finance Committee Report Concludes Stark Law Change Is Necessary to...
In its report, Why Stark, Why Now? [PDF], released June 30, 2016, the Senate Committee on Finance outlines suggested changes to the physician self-referral law, 42 U.S.C. § 1395nn, (the Stark law) in...
View ArticleProposed Cardiac, Hip, and Femur Episode Payment Models Are Next Generation...
The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on July 25, 2016, entitled, Advancing Care Coordination Through Episode Payment Models (EPMs); Cardiac Rehabilitation...
View ArticleCMS Releases Final Rule Addressing Hospice FY 2017 Wage Index, Payment Rates,...
On August 5, 2016, CMS released a final rule addressing fiscal year (FY) 2017 updates to the hospice wage index, payment rates, and quality reporting requirements. Of note, the final rule increases...
View ArticleCMS's Payment Suspensions Wreak Havoc: Understanding the Risks
CMS payment suspensions can cripple any provider's or supplier's operations. Yet, CMS has the authority to impose a payment suspension upon the mere existence of "reliable information" that an...
View ArticleOIG Approves Free Vaccine Refrigeration Systems in Physician Offices
On September 16, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) released Advisory Opinion 16-09, approving a refrigerator manufacturer’s proposal to install a...
View ArticleOIG Finalizes CMP Regulations, Largely as Proposed
On December 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) finalized [PDF] its proposal to update the civil monetary penalty (CMP) regulations – namely,...
View ArticleDespite Uncertain Future of ACA, OIG Issues Final Rule Revising Permissive...
On January 12, 2017, the Department of Health and Human Services (HHS), Office of Inspector General (OIG) published a final rule expanding its permissive exclusion authority while also codifying...
View ArticleOIG Approves Free Lodging and Meals Under "Promotes Access to Care" Exception...
In Advisory Opinion 17-01, published March 10, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) approved an academic medical center's proposal to provide free or...
View ArticleCMS Finalizes New SRDP Disclosure Form and Process
Parties disclosing actual or potential violations of the Stark law will use a new series of forms under CMS's Voluntary Self-Referral Disclosure Protocol (SRDP) process as of June 1, 2017. According to...
View ArticleOIG Unveils New Work Plan Process: Assessing the Impact on Compliance Risk...
On June and July 17, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) released new Work Plan initiatives and, in doing so, announced its intent to update its Work...
View ArticleOIG Advisory Opinion 18-01: Excluded Individual May Serve as Marketing...
In OIG Advisory Opinion 18-01, published February 27, 2018, the OIG concluded a proposed employment arrangement between an excluded individual and a for-profit company selling discounted emergency...
View ArticleCMS Signals Willingness to Revamp Stark for Coordinated Care Efforts
CMS issued a Request for Information (RFI), seeking input from the public on how best to address and mitigate any "undue regulatory impact and burden" of the physician self-referral law ("Stark Law")....
View ArticleStark Law Clarifications in Proposed CY 2019 Physician Fee Schedule
The Centers for Medicare and Medicaid Services (CMS) included two Stark Law clarifications in its proposed CY 2019 Physician Fee Schedule (Proposed Rule). The first change is with respect to the...
View ArticleOIG Releases RFI Focused on Removing Barriers to Value-Based Care
The Department of Health and Human Services, Office of Inspector General (OIG) recently released a request for information (RFI) seeking public input on "how to address any regulatory provisions that...
View ArticleOIG September 2018 Work Plan Update
The OIG added two new items to its Work Plan in the September 2018 update: (1) a review of opioid use in the Indian Health Service (IHS), and (2) a follow-up review of a New York Head Start...
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