A bill introduced in the North Carolina Senate in late March 2025 has the potential to bring major changes to corporate practice of medicine rules in the state, most significantly for physician-owned practices. The bill aims...more
On April 7, Centers for Medicare and Medicaid Services Administrator Seema Verma announced during a White House briefing that the United States Department of Health and Human Services would be distributing $30 billion to...more
We both recently returned from presenting to groups of health care providers on creating and implementing effective compliance programs. Although compliance plans and compliance programs are not new to the health care realm,...more
On January 31, 2017, the Health Resources and Services Administration (“HRSA”) withdrew the 340B Program Omnibus Guidance (often referred to as the Mega Guidance). The guidance addressed a number of significant issues under...more
Receiving an email that your practice has been identified for participating in the HIPAA Privacy, Security, and Breach Rules Audit Program is enough to raise anyone’s blood pressure. The likely response is to open the email...more
On July 27, 2016, the Overall Hospital Quality Star Ratings were released on Medicare’s Hospital Compare website. The Star Ratings represent a summary compilation of individual hospital performance on 64 measures designated...more
Section 1128 of the Social Security Act (42 U.S.C. 1320a–7) (available here) established mandatory and permissive authority for exclusion of health care providers from Federal health care programs based on provider conduct. ...more
On March 11, 2016, CMS proposed implementation of a new two-phase model for drugs reimbursed under Part B of the Medicare Program (“the Proposed Model”). Drugs reimbursed under Part B include drugs administered in hospital...more
5/2/2016
/ Alternative Payment Models (APM) ,
Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Hospitals ,
Medicare Part B ,
Outpatient Services ,
Physicians ,
Prescription Drugs ,
Proposed Regulation ,
Rural Health Care Providers ,
Value-Based Purchasing
The Medicare Shared Savings Program provides financial rewards to Accountable Care Organizations (ACO’s) that successfully manage overall health care costs for a defined population of beneficiaries while meeting quality of...more
Provider-based off-campus hospital outpatient departments (OC-HOD’s) established after November 1, 2015 will be subject to a new site-neutral payment limitation starting Jan. 1, 2017 as a result of provisions in the Balanced...more
The Cybersecurity Act of 2015, included in the Omnibus Appropriations and Tax Reform Package adopted into law in December, 2015, specifically addresses cybersecurity in the healthcare industry....more
Narrow networks (managed care provider networks that include a limited choice of participating healthcare providers and suppliers) have been widely criticized by consumers and consumer-rights groups, particularly in light of...more
Yesterday, the Office of Inspector General (“OIG”) published “Practical Guidance for Health Care Governing Boards on Compliance Oversight.” The guide is intended as an educational resource for the boards of healthcare...more
In March 2013, the Federal Trade Commission, together with the Idaho Attorney General, filed a complaint seeking to block St. Luke’s Health System’s planned acquisition of Saltzer Medical Group P.A., a multi-specialty...more
In May 2014, the American Hospital Association filed suit against the United States Department of Health and Human Services seeking to compel Administrative Law Judges (ALJs) to comply with applicable statutory deadlines for...more
After objecting to the release of hospital reimbursement rates mandated under North Carolina’s Health Care Cost Reduction and Transparency Act of 2013 (NCGS Section 131E-214.5), Blue Cross Blue Shield of North Carolina...more
This paragraph (or some variation) finds its way into lots of contracts when one or both of the parties to the contract are participants in the health care industry...more
In very broad terms, the 340B program allows some safety-net health care providers to provide qualifying patients with affordable prescription drugs. In January, the Office of Pharmacy Affairs (OPA) of the Health Resources...more