One could forgive the healthcare industry for thinking someone drove Doc Brown’s DeLorean time machine through One First Street when it awoke on Friday, June 28, to a blast from the past....more
7/11/2024
/ Administrative Procedure Act ,
Audits ,
Centers for Medicare & Medicaid Services (CMS) ,
Chevron Deference ,
Government Agencies ,
Health Care Providers ,
Judicial Authority ,
Loper Bright Enterprises v Raimondo ,
Medical Reimbursement ,
Medicare ,
Overpayment ,
Regulatory Authority ,
SCOTUS ,
Statutory Interpretation
Recently, Optum Behavioral Health (“Optum,” the services division for UnitedHealth Group) has initiated overpayment recovery actions against numerous licensed clinical social workers (“LCSWs”) across the country for services...more
On October 31, 2019, the Office of General Counsel for the U.S. Department of Health and Human Services (HHS) issued an important memo from Kelly M. Cleary, CMS Chief Legal Officer, and Brenna E. Jenny, Deputy General...more
12/5/2019
/ Administrative Procedure Act ,
Azar v Allina Health Services ,
Centers for Medicare & Medicaid Services (CMS) ,
Denial of Benefits ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
Health Care Providers ,
Hospitals ,
Local Coverage Determination (LCD) ,
Low-Income Issues ,
Medicare ,
Medicare Advantage ,
Medicare Part A ,
Medicare Part C ,
Notice and Comment ,
Overpayment ,
Pay Reductions ,
Provider Payments ,
Reaffirmation ,
Retroactive Application ,
Rulemaking Process ,
SCOTUS ,
Substantive Rule ,
Universal Health Services Inc v United States ex rel Escobar ,
Vacated
On Jan. 20, 2016, a federal district court in the Western District of Texas affirmed a decision of the Medical Appeals Council (Appeals Council) affirming a CMS contractor’s extrapolation methodology used to assess an...more