On December 27, 2013, the Centers for Medicare & Medicaid Services (“CMS”) issued revisions to Chapter 15 of the Medicare Program Integrity Manual. The key clarifications/updates of interest to providers include: • Instructions for processing disclosures of final adverse actions reported by providers and suppliers or law enforcement agencies; •…
On December 23, 2013, the Department of Health and Human Services (“HHS”) announced the participation of 123 new Accountable Care Organizations (“ACOs”) in the Medicare Shared Savings Program. This step is intended to further advance Medicare’s goal of providing its beneficiaries with access to high-quality, coordinated care nationwide. The newly…
On December 10, 2013, Minnesota Congressman Erik Paulsen introduced a bill into the House of Representatives that he believes will streamline and enhance the U.S. healthcare delivery system. The bill, entitled the “Diagnostic Imaging Utilization Act of 2013” directs Medicare to develop a system whereby physicians ordering advanced imaging (“AI”)…
The Centers for Medicare and Medicaid Services (“CMS”) has released the final version of its 2014 Medicare Physician Fee Schedule (“MPFS”) that determines physician reimbursement for services furnished to Medicare beneficiaries. In addition to adjusting the various formulas that are used to determine payment amounts, the MPFS includes a number…
On December 2, 2013, the Office of Inspector General (“OIG”) published an advisory opinion in which it considered whether a charitable organization’s (the “Requestor”) proposal to provide monetary assistance, including Medicare premium assistance, to financially needy patients suffering from a rare genetic disorder (the “Disorder”) violated the Anti-Kickback Statute (“AKS”)…
On November 21, 2013, the Office of Inspector General (“OIG”) published its Strategic Plan for 2014-2018. The Plan outlines the OIG’s vision for achieving its mission to protect the Department of Health and Human Services (“DHHS”) through a number of goals and priorities. The OIG intends to use the Plan…
On November 12, 2013, the Office of Inspector General (the “OIG”) released an unfavorable Advisory Opinion in response to an anesthesiology practice’s (the “Requestor”) inquiry. Specifically, the OIG found that a psychiatry group’s (the “Psychiatry Group”) proposal to pay the Requestor a per-diem rate for anesthesia services while keeping any…
On Wednesday, October 23, 2013, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services released a report detailing its findings from a study it completed on the prevalence and use of devices supplied by physician owned distributors (“PODs”). The report, issued in response to…
Michigan Attorney General Bill Schuette along with Steve Arwood, Director of the Michigan Department of Licensing and Regulatory Affairs, and State Senator Joe Hune, recently announced their plan to collaborate on a bill designed to strengthen Michigan’s regulation and oversight of compounding pharmacies. Compounding pharmacies have been under increased scrutiny…
Jessica Gustafson, Esq. and Abby Pendleton, Esq., co-chairs of the firm’s Medicare and RAC department authored an ABA Health eSource article titled “The Latest Development in Medicare Audits: Supplemental MEdical Review Contractor (“SMRC”) Audits.” To view this article click here. The article discusses the Center for Medicare and Medicaid Services’s…