06th July 2009
In recent years, the Centers for Medicare and Medicaid Services (“CMS”) has heavily scrutinized the terms and conditions under which Medicare will pay for diagnostic testing services, resulting in heightened regulatory action targeting certain diagnos...
06th July 2009
The 2008 Medicare Physician Fee Schedule (MPFS) was published in the Federal Register on November 27, 2007. For the most part, the 2008 MPFS final rule will take effect January 1, 2008. This article will focus on two areas of the MPFS final rule that wi...
06th July 2009
Over the past few years, there has been more intense focus on medical staff actions related to disruptive conduct of physicians.
In the past, many hospitals did not have any policies, procedures or guidelines to assist them when faced with the unprofes...
06th July 2009
Physician recruitment is a highly regulated activity and thus physicians involved in recruitment arrangements should understand the legal issues involved. This article generally addresses two primary laws involved in the relationship but does not cover a...
06th July 2009
Introduction
On March 16, 2000, the United States Department of Health and Human Services Office of Inspector General (the “OIG”) published its first “Compliance Program Guidance” for Nursing Facilities” (the “Guidance” or “2000 Guidanc...
06th July 2009
Physicians, providers and suppliers providing services under Part A of Medicare, who have been subject to Medicare audits or claim denials resulting in overpayment demands, are aware that, currently if a Medicare fiscal intermediary identifies an alleged ...
06th July 2009
When undertaking compliance measures, it is not uncommon to hear a physician attempt to justify the presence of billing errors by saying that the far majority of the billing is accurate and that one cannot worry too much about an occasional error here or ...
06th July 2009
Earlier this year, Blue Cross Blue Shield of Michigan (“BCBSM”) published its amendment to the BCBSM Evidence-of-Need (“EON”) requirements for ambulatory surgery facilities (“ASFs”). These changes, in pertinent part:
1. Correlated the EON...
06th July 2009
I. INTRODUCTION
Attention radiology providers and suppliers: Get ready for increased Medicare auditing activity. The Centers for Medicare and Medicaid Services (CMS) Recovery Audit Contractor (RAC) program has been made permanent and is expanding nat...
06th July 2009
The financial pressure on hospitals, physicians and other healthcare providers, as a result of increased scrutiny of claims and audit activity by third party payors, will not end soon. To the contrary, as part of the Tax Relief and Health Care Act of 20...
05th June 2009
The Federal Stark law prohibits physicians from referring Medicare/Medicaid beneficiaries to an entity in which they (or an immediate family member) have a financial relationship for designated health services (“DHS”), unless an exception applies. DH...
05th June 2009
Laser treatment has been utilized with limited frequency for certain dermatological applications such as the removal of tattoos, acne scars, port wine stains, and skin blemishes for over a decade. However, in recent years, laser treatment for hair remova...
05th June 2009
On August 19, 2008, the Centers for Medicare and Medicaid Services (“CMS”) published final Stark rules in its 2009 Final Hospital Inpatient Prospective Payment Systems rule (“Final Rule”). The Final Rule contains several important revisions to th...
05th June 2009
Recently, the Centers for Medicare and Medicaid (“CMS”) entered into the pay for performance arena with the Physician Quality Reporting Initiative (“PQRI” or “Initiative”) aimed at improving the quality of health care. Participants in the Ini...
05th June 2009
On December 28, 2007, the Centers for Medicare and Medicaid Services (CMS) displayed a final rule announcing that it was delaying the effective date of the majority of the newly revised anti-markup rule until January 1, 2009. CMS’ announcement came just...
