The Department of Justice (DOJ) and qui tam plaintiffs are pressing on with their pursuit of healthcare entities for False Claims Act cases and other enforcement actions. Having a compliance program that is effective in...more
CMS’ 340B Rate Cut Continues to Dampen Hospital Outpatient Expansion Efforts -
Hospitals hoping to benefit from favorable 340B drug pricing when acquiring independent physician practices for conversion to hospital...more
11/27/2019
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Final Rules ,
Health Care Providers ,
Healthcare ,
Hospitals ,
Medical Reimbursement ,
Off-Campus Departments ,
OPPS ,
Outpatient Services ,
Section 340B ,
Stark Law
KEY POINTS -
- A new CMS Medicare Rule for Calendar Year 2020 reduces the default level of supervision required for hospital outpatient therapeutic services in all hospitals, from "direct" to "general" supervision.
-...more
11/13/2019
/ Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Final Rules ,
Medicare ,
Medicare Beneficiaries ,
New Rules ,
Outpatient Prospective Payment System (OPPS) ,
Outpatient Services ,
Physicians ,
Supervision ,
Therapeutic Services
Key Points
- On October 17, 2019, the OIG proposed rules to add safe harbor protections for coordinated care and associated value-based arrangements.
- The OIG proposed several new safe harbors: value-based...more
10/22/2019
/ Anti-Kickback Statute ,
Beneficiary Inducement ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Comment Period ,
Cybersecurity ,
Department of Health and Human Services (HHS) ,
EHR ,
Medicare Shared Savings Program ,
OIG ,
Proposed Rules ,
Safe Harbors ,
Stark Law ,
Telehealth ,
Telemedicine ,
Value-Based Care
"CMS Proposes Sweeping Revisions to the Stark Law" is Part I of a two-part series discussing the US Department of Health and Human Services' (DHHS) recent proposed rules revising the Stark Law and the Anti-Kickback Statute as...more
10/18/2019
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Physicians ,
Proposed Rules ,
Public Comment ,
Regulatory Requirements ,
Safe Harbors ,
Stark Law ,
Value-Based Care
On May 3, CMS issued a draft letter to State Survey Agency Directors regarding "Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities" ("Guidance") that is intended to provide clarity on how...more
Southern Baptist Hospital of Florida (Hospital) was sued in a medical malpractice action in which the plaintiff sought to discover records relating to "adverse medical incidents" that occurred at the Hospital and involved any...more
The federal Occupational Safety and Health Administration (OSHA) recently released a memorandum clarifying its enforcement efforts against the inpatient health care and nursing home industries. The list of covered facilities...more
In this presentation:
- Top 5 Fraud and Abuse Risks Facing Health Systems
- Results of Enforcement Action
- Top 5 Steps Health Systems Can Take To Minimize Fraud & Abuse Risk
- Non-Compliant...more