Articles and Blogs

Executive Summary On October 2, 2012, the Office of Inspector General (“OIG”) published its Work Plan for Fiscal Year (“FY”) 2013 (“Plan”).  The Plan, which is published annually and describes the OIG’s new and ongoing audit and enforcement priorities for the upcoming year, is helpful in identifying corporate compliance risk areas and providing focus... READ MORE

On September 27, 2012 CMS issued an advance copy of the State Operations Manual (“SOM”) revisions to Appendix P of the SOM which addresses Long Term Care Facility survey protocol. The SOM guidance also makes changes to various survey forms resulting from the new quality measures reports. READ MORE

This Health Law News article is Part VII in a series discussing the new governance study, “Governance in Large Nonprofit Health Systems: Current Profile and Emerging Patterns.” The full Report is available here. Part I – Executive Summary was published in Hall Render’s Health Law News on August 8, 2012, Part II – Public... READ MORE

Introduction The Centers for Medicare & Medicaid Services (“CMS”) will withhold 1% of Medicare reimbursement payments as part of the Value-Based Purchasing Program (“VBP Program”) beginning today, October 1, 2012.  This money will be used to fund incentive payments for participating hospitals in the VBP Program.  Under the VBP Program, hospitals compete with one... READ MORE

Executive Summary On September 27, 2012, the Department of Health and Human Services Office of Inspector General (“OIG”) issued its findings resulting from a study of Medicare Part D billings and payments for Schedule II drug refills.  Schedule II drugs have the highest potential for abuse of any prescription drug in the United States... READ MORE

Introduction On July 26, 2012, with further amendment on August 14, 2012, the Department of Justice announced that its Civil Rights Division will be partnering with U.S. Attorneys’ offices across the country to make sure that people with disabilities have access to medical information in an understandable format.1 This initiative – the Barrier-Free Health... READ MORE

This Health Law News article is Part VI in a series discussing the new governance study, “Governance in Large Nonprofit Health Systems: Current Profile and Emerging Patterns.” The full Report is available here. Part I – Executive Summary was published in Hall Render’s Health Law News on August 8, 2012, Part II – Public... READ MORE

Executive Summary On August 23, 2012, the Department of Health and Human Services Office of the Inspector General (“OIG”) issued OIG Advisory Opinion 12-10 (the “AO”).  The OIG reviewed a proposed arrangement to provide free insurance pre-authorization services to referring physicians and concluded that while the free services potentially could be characterized as prohibited... READ MORE

Executive Summary This is the second in a series on Medicare Disproportionate Share Hospital (“DSH”) payment issues and is designed to provide hospitals with a practical approach for determining if they want to pursue different DSH appeal issues. On September 11, 2012, CMS posted the 2010 DSH-SSI (Supplemental Security Income) ratios.  As reported previously... READ MORE

On September 17, 2012, the Department of Health and Human Services (“HHS”) announced that it had reached an agreement with two health care providers who were operating as a single affiliated covered entity for purposes of HIPAA (collectively referred to as the “Providers”) to settle potential violations of the Security Rule of the Health... READ MORE