Articles and Blogs

On October 30, 2014, CMS issued its pre-released copy of the Final CY 2015 Home Health Prospective Payment System Rule (“Final Rule”). The Final Rule adopts many of the proposals found in the proposed regulations that were published by CMS earlier this year (“Proposed Rules”). Notably, the Final Rule also contains CMS’s responses to... READ MORE

The recent report by the Institute of Medicine on the United States graduate medical education system, Graduate Medical Education That Meets the Nation’s Health Needs1 (“IOM Report”), advances many structure reform themes that have appeared in other assessments in recent years.  However, it goes much further.  The IOM Report calls for fundamental changes to... READ MORE

On Friday, October 24, 2014, the IRS released an advance version of Notice 2014-67, (1) adding a new 5-year safe harbor to Revenue Procedure 97-13 (“Rev. Proc. 97-13”) and providing for the inclusion of quality-based incentive payments in management and service contracts for facilities financed with tax-exempt bond proceeds; and (2) offering interim guidance for... READ MORE

As the first quarantine period in Texas passes without additional infections, the focus is on improving preparedness for Ebola while ensuring accurate information is made available to the public. To support preparedness efforts, the CDC and other health care organizations have taken steps to provide health care organizations and providers around the country with critical... READ MORE

Executive Summary In recently issued, virtually identical Advisory Opinions Nos. 14-07 and 14-08, the Department of Health and Human Services Office of the Inspector General (“OIG”) opined that licensed insurers offering Medigap policies to Medicare beneficiaries may contract with preferred hospital organization network hospitals for discounted Medicare inpatient deductibles and, in turn, issue premium... READ MORE

Overview The Department of Health & Human Services Office of Inspector General (“OIG”) recently released a Special Advisory Bulletin on the fraud and abuse implications of pharmaceutical manufacturers offering copayment coupons to reduce or eliminate the cost of out-of-pocket copayments for brand-name drugs.  The Special Advisory Bulletin and the concurrent OIG Office of Evaluations and... READ MORE

The Department of Health and Human Services Office of Inspector General (“OIG”) recently issued a proposed rule that adds to and amends the Anti-Kickback Statute safe harbors and provides guidance regarding the Civil Monetary Penalty rules for beneficiary inducements and gainsharing (“Proposed Rule”).1 The Proposed Rule addresses several issues regarding the way providers interact... READ MORE

Executive Summary On October 17, 2014, the Centers for Medicare & Medicaid Services (“CMS”) announced1 the extension of the November 2, 2011 interim final rule with comment that established waivers of some federal fraud and abuse laws as applied to Accountable Care Organizations (“ACOs”) participating in the Medicare Shared Savings Program (the “Program”). Without... READ MORE

Ebola concerns continue to grow this week as two nurses who cared for an Ebola patient in Texas test positive for the virus. Hospitals, physician offices, clinics, emergency medical services (“EMS”), physical therapy offices and other health care providers, regardless of location, need to prepare now for a possible Ebola patient. Care for an Ebola patient... READ MORE

WEBINAR As we move into the second year of open enrollment through the Health Insurance Exchanges, it is time to revisit the issue of Premium Support Programs, an issue that had a bit of a rollercoaster ride during last year’s open enrollment. Has the dust settled enough that you can safely implement a Support... READ MORE