In the Office of Inspector General’s (OIG) Advisory Opinion 11-02, the OIG examined a proposed arrangement in which the Requestor–a non-profit, tax-exempt corporation that operates an outpatient acute care hospital–would provide complimentary transportation services to patients and their families at physicians’ offices located on, or contiguous to, the Requestor’s campus (Physicians) to the Requestor’s acute […]

Following a December challenge in the Northern District of Texas, the ninth circuit (Los Angeles Haven Hospice, Inc. v. Sebelius, No. 09-56391 (9th Cir. Mar. 15, 2011)) and the fifth circuit (Lion Health Servs. V. Sebelius, No. 10-10414 (5th Cir. Mar. 11, 2011)) have both ruled that the hospice cap regulation (42 CFR 418.309(b)) is […]

Section 6407 of the Patient Protection and Affordable Care Act requires a face-to-face encounter for home health and hospice patients to qualify for Medicare coverage. On March 12, 13 prominent medical societies and advocacy groups sent a letter to the Centers for Medicare and Medicaid Services (CMS) requesting a postponement until, at least, July 1 […]

On March 15, 2011, US Attorney General Eric Holder, Secretary of Health and Human Services (HHS) Kathleen Sebelius and Inspector General Daniel Levinson visited Detroit to participate in the fifth regional health care fraud prevention summit. These summits bring together a wide array of federal, state and local partners, beneficiaries, providers and other interested parties […]

According to an article in Modern Physician, most faculty physicians experienced an increase in their salaries from 2009 to 2010. Based on a report from the Medical Group Management Association (MGMA), “the median compensation for primary-care faculty physicians was $163,704, up 3.47% from $158,218 in 2009, and the median pay for specialty care faculty was […]

Since the signing of the Patient Protection and Affordable Care Act (PPACA) last year, there has been considerable attention and interest within the industry towards accountable care organizations (ACOs). Accompanying this focus has been a series of questions regarding the compositional requirements, as well as the operational and structural opportunities to be afforded to (and […]

According to the Associated Press (March 6, 2011), an Indiana pharmacist, John D. Love (owner of the Terre Haute Prescription Shop) “faces a possible 10-year prison sentence if convicted of health care fraud and money laundering in a scheme that netted him more than $3.57 million, federal prosecutors say.” The amount of the case qualifies […]

WPS, the Legacy Part B Medicare Administrative Contractor for Illinois, Michigan, Wisconsin and Minnesota, has issued recent guidance regarding documentation of discard or waste for drugs and biologicals as well as missing information on the Medicare CMS-855 provider enrollment applications. Notably, WPS voices CMS’ direction that physicians, hospitals, and other providers “make good faith efforts […]

Gov. Snyder’s Executive Orders 2011-4 and 2011-5 reorganized DELEG, changing the name to the Department of Licensing and Regulatory Affairs (DLRA). Other notable changes include – Transferring the Bureau of Health Professions, the Bureau of Health Systems and the Controlled Substances Advisory Commission from the Department of Community Health to the DLRA; – Creating an […]

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