Articles Posted in Health Law News

The OIG will examine a number of Home Health Agency (HHA) issues, a number of which are provided in this entry. The OIG will scrutinize payments made under Part B’s HHA prospective payments. The Social Security Act requires that all services provided under a plan of care of an HHA be paid to the HHA, […]

The OIG will review a number of payment systems including, but not limited to, capital payments, the provider-based status payments, the inpatient prospective payment system, excessive Medicare payments, Medicare disproportionate share payments, duplicate graduate medical education payments, payments for diagnostic radiology services in emergency departments, and compliance with the Medicare conditions of participation (CoP) for […]

In an audit of Michigan’s Medicaid program, the Office of Inspector General (OIG) found that Michigan’s Medicaid agency did not report on the CMS-64 $3 million in over payments–a direct violation of Section 1903(d)(2) of the Social Security Act (Act). Of that $3 million not reported, $2,198,100 was the federal government’s share. The audit revealed […]

On October 4, 2010, the OIG released its Work Plan for the FY of 2011. Throughout the week, we will be posting on various aspects of the Work Plan pertinent to our clients and our readers in the following areas: • Hospitals • Home Health Agencies • Hospices • Evaluation and Management Services • Imaging […]

On September 7th, the Joint Commission announced that, commencing in July 2011, the Joint Commission will extend the accreditation process of accrediting ambulatory health care organizations to those who choose the Primary Home option. “A Primary Care Home is a model of care whereby services are provided to patients by a primary care provider or […]

The Federal Trade Commission (“FTC”), Centers for Medicare and Medicaid Services (“CMS”), and Department of Health and Human Services Office of Inspector General (“OIG”) have announced their plans to co-host an October 5th workshop on accountable care organizations (“ACOs”). According to a September 8th News Release, the workshop is intended principally to assist providers in […]

The OIG released Advisory Opinion 10-13 on August 31, 2010, concerning a proposed-arrangement where a hospital would be providing pre-authorization services for diagnostic imaging. Requestor, a non-profit hospital, provides diagnostic imaging services to patients. Because many commercial insurers have begun requiring pre-authorization prior to covering diagnostic imaging services, the hospital has proposed to provide free […]

As the Wall Street Journal reported on August 9th, health-insurance companies progressively are initiating programs to equip doctors with high-tech patient records. Even with all of the focus on electronic health records (“EHR”), an estimated 80% of U.S. physicians and 90%of hospitals continue to use paper records. As HLP has discussed in a number of […]

Attorney General of New York, Andre Cuomo, initiated an investigation into health care credit cards after receiving a substantial number of complaints from consumers who were convinced by doctors and dentists to sign up for them. The investigation will examine the financial incentives providers received from promoting the cards. Subpoenas have already been issued to […]

On July 30, the OIG released advisory opinion no 10-11 (the “Opinion”) which favorably reviewed a company’s proposal to encourage health care providers to use its online program for scheduling meetings with manufacturer representatives by offering the health care provider an opportunity to select a public charity to which the company would make a monetary, […]

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