On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) final rule (Final Rule), which finalized several noteworthy policies related...more
Although the 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program Final Rule ("Final Rule") was published on May 1, 2020, there are prohibitions and exceptions regarding...more
The Department of Health and Human Services has released extensive and significant revised final rules governing the Physician Self-Referral Law (the Stark law) and the Medicare Anti-Kickback Statute (AKS) in furtherance of...more
12/21/2020
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Patients ,
Payment Systems ,
Physicians ,
Safe Harbors ,
Self-Referral ,
Stark Law ,
Value-Based Care
In its Advisory Opinion (AO), AO 20-04, HHS Office of the Inspector General (OIG) determined that the requestor, a charitable organization that locates, buys and forgives patient medical debt, may purchase or receive as...more
The Coronavirus Preparedness and Response Supplemental Appropriations Act, which was enacted on March 6, 2020, allows the Secretary of the United States Department of Health and Human Services (HHS) to waive certain...more
3/21/2020
/ Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Emergency Response ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Medicare ,
OCR ,
Physicians ,
Relief Measures ,
Telehealth ,
Telemedicine ,
Waivers
The Centers for Medicare & Medicaid Services (CMS) recently updated its advisory opinion regulations, codified at 42 CFR §§ 411.370 through 411.389, in a final rule issued November 15, 2019. The update liberalizes and...more
12/23/2019
/ ACOs ,
Advisory Opinions ,
Amended Rules ,
Centers for Medicare & Medicaid Services (CMS) ,
Certifications ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
Final Rules ,
Health Care Providers ,
Physicians ,
Public Comment ,
Rescission ,
Self-Referral ,
Stark Law
In Advisory Opinion 19-04, published September 10, 2019, the Office of Inspector General (OIG) approved an online health care directory operated on a per-click or per-booking fee arrangement. The proposed directory will be...more
9/24/2019
/ Advisory Opinions ,
Anti-Kickback Statute ,
Beneficiary Inducement ,
Fees ,
Fraud and Abuse ,
Health Care Providers ,
Marketing ,
OIG ,
Pay-Per-Click ,
Physicians ,
Price Transparency ,
Provider Payments ,
Safe Harbors ,
Websites
The Director of the Civil Fraud Section of the Department of Justice (DOJ), Michael Granston, issued a memo in January 2018 noting the recent increase in qui tam lawsuits filed under the False Claims Act (FCA). The Granston...more
1/31/2019
/ Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Health Care Providers ,
Motion to Dismiss ,
Prosecutorial Discretion ,
Public Interest ,
Qui Tam ,
Relators ,
Resource Management ,
Split of Authority ,
The Granston Memo
Advanced Medical Technology Association (AdvaMed) has released the first update to its Code of Ethics on Interactions with U.S. Health Care Professionals (the Code) since July 2009. The new Code, announced January 9, 2019,...more