Earlier this month, Transmittals to the State Operations Manual for ASCs (Appendix L) implemented certain clarifications/changes to the anesthetic risk assessment, H&P and pre-surgical evaluation Conditions of Participation at ASCs, effective 5.13.11. The new standards from the Transmittal are set forth below, followed by the provisions in which these new…
According to the Medical Group Management Association (“MGMA”), physicians enjoyed an employee’s market in 2010. Based on MGMA survey data, 56% of first-year physicians accepted paid relocation packages and signing bonuses last year. Also, 12% of first-year doctors obtained loan-forgiveness packages. The MGMA survey also found that first-year specialists in…
In its proposed rule for accountable care organizations (“ACOs”), the Centers for Medicare and Medicaid Services (“CMS”) includes mandatory compliance plans as an element of its ACO-program integrity efforts. The compliance plan must include at least the following elements: • A designated compliance officer who is not legal counsel to…
May 10, 2011, the Miami Lakes, Florida council passed a zoning ordinance requiring pain clinics in its town to obtain a special permit. A pain clinic’s grand opening advertisement featuring the words “pain” and “opiates” put a Miami Lakes councilman in fear of potential pill-mill activity coming to town and…
In order to assist individuals interested in learning more about the fundamentals of health care compliance and help answer questions about what to do when compliance issues arise, the Office of Inspector General recently posted the HEAT Provider Compliance Training slide presentation and written materials which accompany its compliance training…
During late March, the Centers for Medicare and Medicaid Services (“CMS”) proposed a rule regarding Accountable Care Organizations (“ACOs”) and the Medicare Shared Savings Program, which will make payments of shared savings to ACOs (“Proposed Rule”). The Proposed Rule describes the amount of financial risk the participants will face and…
The Centers for Medicare & Medicaid Services (“CMS”) released the latest edition of its Medicare Compliance Newsletter. The publication contains examples of Medicare billing errors and guidance on how to avoid such mistakes. The newsletter may be viewed here. For more information regarding compliance or for assistance defending an audit,…
It is often instructive to review the thinking of health care decision-makers as a tool to acquire insight on the direction of health care policy. In this regard, Dr. Donald Berwick, the administrator of the Centers for Medicare & Medicaid Services (“CMS”), recently authored an Op-Ed in the Wall Street…
Healthcare providers are more frequently utilizing social media to market their practices and to dispense health information. In order to protect the patient-physician relationship and ensure a continued positive internet presence for healthcare providers, the American Medical Association (“AMA”) adopted recommendations for physician use of social media. The guidelines recommend…
Based on a recent report from the Office of Inspector General (“OIG”), Medicare permitted $38 million of improper claims for interpretation and reports of radiology services based on insufficient documentation in hospital emergency departments in 2008. This includes a 19 percent erroneous allowance of claims for interpretation and reports for…