On December 4, 2023, CMS issued an interim final rule (the Interim Rule) (RIN 0938-AV26) to implement new enforcement authorities that CMS may use if states fail to comply with new reporting requirements or with federal...more
12/15/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Coronavirus/COVID-19 ,
Enforcement ,
Families First Coronavirus Response Act (FFCRA) ,
FMAP ,
Interim Final Rules (IFR) ,
Medicaid ,
Public Health Emergency ,
Reporting Requirements ,
Social Security Administration (SSA)
On October 11, 2023, CMS published a final rule (the Final Rule) regarding how and when CMS will impose civil monetary penalties (CMPs) for Medicare secondary payers (MSPs) that untimely report required information. The Final...more
10/19/2023
/ Audits ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Employer Group Health Plans ,
Final Rules ,
Medicare ,
Medicare Beneficiaries ,
Medicare Secondary Payer Act ,
Reimbursements ,
Social Security Act ,
Statute of Limitations
On September 30, 2021, OIG posted Advisory Opinion No. 21-14 regarding a chiropractor’s proposal to extend an existing discount program covering a package of services to include federal health care program beneficiaries. OIG...more
10/14/2021
/ Advisory Opinions ,
Anti-Kickback Statute ,
Beneficiary Inducement ,
Civil Monetary Penalty ,
Discounts ,
Healthcare ,
Medicare ,
Medicare Part B ,
OIG ,
Payment Systems ,
Physician Medicare Reimbursements
Last week, OIG posted Advisory Opinions Nos. 21-03, 21-04, and 21-05 relating to three near-identical arrangements between Medigap plans and Preferred Hospital Organizations (PHOs). The arrangements involve (i) a discount on...more