On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...more
10/4/2023
/ Billing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Fees ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
No Surprises Act (NSA) ,
Out of Network Provider ,
Surprise Medical Bills ,
U.S. Treasury
Although the No Surprises Act was signed into law almost three years ago and has been in effect for the past year and a half, there have been numerous delays in implementation and execution due to the complexity of elements...more
Does violating requirements amount to fraud under the False Claims Act (FCA) when the requirements allegedly violated are unclear? There is currently a circuit split and petitions for review pending to the Supreme Court as to...more
1/11/2023
/ Ambiguous ,
Centers for Medicare & Medicaid Services (CMS) ,
Fair Credit Reporting Act (FCRA) ,
False Claims Act (FCA) ,
Fraud ,
Health Care Providers ,
ICD Codes ,
Medical Reimbursement ,
Medicare Advantage Organizations (MAOs) ,
Motion to Dismiss ,
Regulatory Requirements ,
SCOTUS
On Friday, December 2, 2022, the Centers for Medicare & Medicaid Services (CMS) issued an FAQ regarding the Good Faith Estimate (GFE) and Convening Provider/Facility requirements in the Federal No Surprises Act. The issued...more
Courts are grappling with unique questions in the context of managed care programs in False Claims Act (FCA) cases. But are they getting it right? Two questions trending in courts relate to: (1) materiality under the FCA when...more
9/23/2022
/ Anti-Kickback Statute ,
Beneficiaries ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Liability ,
Department of Justice (DOJ) ,
Dismissal With Prejudice ,
False Claims Act (FCA) ,
Fee-for-Service ,
Fraud ,
Health Care Providers ,
Managed Care Contracts ,
MCOs ,
Medicare ,
Medicare Advantage ,
Risk Adjustment Formula ,
SCOTUS ,
Universal Health Services Inc v United States ex rel Escobar