Get ready: the Centers for Medicare and Medicaid Services (CMS or Medicare) Recovery Audit Contractor (RAC) program has been made permanent and is expanding nationwide. All Medicare providers and suppliers should begin to prepare now for increased Medicare scrutiny. Hospitals and health systems nationwide can expect RAC auditing activity and…
Health Law Attorney Blog
Recent Developments and Key Legal Issues Impacting Diagnostic Imaging Services, Part 2
This article is the second part of a 2 part series addressing recent federal regulatory action targeting diagnostic imaging arrangements. Part 1 (published in the January/February 2009 issue of Radiology Management) focused solely on some of the more significant changes to the federal Stark regulations. Part 2 will summarize some…
Recent Developments and Key Legal Issues Impacting Diagnostic Imaging Services, Part 1
In recent years, the diagnostic imaging services industry has been intensively scrutinized by the federal government, as evidenced by heightened regulatory action targeting certain diagnostic imaging arrangements, such as changes to the federal Stark Law (that restrict the flexibility of structuring diagnostic imaging arrangements), expansion of the federal anti-markup prohibition,…
The Continued Relevance of the Stark Law’s IOASE: In-Office Imaging Arrangements Remain Viable
Recent legislative initiatives to restrict (or eliminate) the Stark Law’s In-Office Ancillary Services Exception (IOASE) are by no means a new phenomenon. Rather, over the last few years, the Centers for Medicare and Medicaid Services (CMS) has introduced several significant proposals targeting the provision of diagnostic imaging (and other ancillary…
CBO Says Healthcare Bill is NOT Budget Neutral
The Affordable Health Choices Act (Act) has been hotly contested by many Republicans, some Democrats, and now, is being put in place by Congressional Budget Office (CBO). The CBO is the final authority when it comes to the cost of legislation and it announced that the Act is not “budget…
2010 Proposed Physician Fee Schedule – Advanced Imaging Updates
According to the 2010 Proposed Physician Fee Schedule (PPFS), as of January 1, 2012, the Center for Medicare and Medicaid Services (CMS) proposes that Medicare payment be made only for the technical component (TC) of advanced diagnostic imaging services to suppliers who have met the accreditation requirements set forth by…
The Blue Has Given Us the Green to See the Long-Awaited Healthcare Bill
House Democrats released the long-awaited healthcare bill today. In its 1018 pages, it describes its 10-year, $1 trillion venture that includes the highly controversial government insurance plan. As Democrats have publicized, this bill will greatly expand healthcare insurance coverage to Americans without insurance and, at the same time, slow the…
Following Other States, Michigan’s Attorney General Looks to Implement a Michigan Office of Medicaid Inspector General
Wednesday, Michigan’s Attorney General–Michael Cox–alongside Republican legislators supported a bill being drafted by the Michigan legislature that would create a Michigan Office of Medicaid Inspector General (OMIG). This office would convert the already-in-place Medicaid Fraud Control Unit to an office that audits Medicaid activities and helps detect and prevent Medicaid…
The Red Flags Era is Approaching, Are You Ready?
The August 1st Red Flags start date is quickly approaching and many creditors (yes, that means you, doctors) are preparing themselves for the new regulations. For those entities that have not drawn up their Red Flags programs yet, there is still time and the Federal Trade Commission (FTC) has provided…
Attention All Anesthesiologists – The 2010 CMS Proposed Physician Fee Schedule Has Been Posted!
If you’re a physician, the Centers for Medicare and Medicaid Services (CMS) Proposed Physician Fee Schedule for 2010 affects you. As a matter of fact, according to the proposed rule, Medicare will cut spending on physician services by 21.5% beginning in January 2010. The finalized fee schedule will be released…