Articles and Blogs

Centers for Medicare & Medicaid Services (“CMS”) is revising its Nursing Home Compare Five-Star Quality Rating System to add a red alert icon to a skilled nursing facility’s profile if the facility has had a high-level abuse citation and/or repeat abuse citations. Changes to CMS Nursing Home Compare Website On October 7, 2019, CMS announced…Read More

On September 6, 2019, OIG issued Advisory Opinion No. 19-05 (“the Opinion”) regarding the proposed purchase of real estate from an entity owned and managed, in part, by an excluded individual. The facts that gave rise to the Opinion involved a community health center receiving federal grant funding and Medicare reimbursement which was looking to…Read More

On October 9, 2019, both the Health and Human Services Office of Inspector General (“OIG”) and Centers for Medicare & Medicaid Services (“CMS”) issued proposed rules pertaining to the Anti-Kickback Statute safe harbor and Civil Monetary Penalties Law exception for EHR Donations (“EHR Donation Rules”), as well as a new safe harbor and exception for…Read More

On October 9, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released a much anticipated proposed rule (“Proposed Rule”) aimed at modernizing and streamlining the Federal Stark Regulations. The Proposed Rule is one component of the Department of Health and Human Services (“HHS”) recently launched “Regulatory Sprint to Coordinated Care” and is intended to…Read More

On October 9, 2019, the Health and Human Services Office of Inspector General (“OIG”) released a proposed rule pertaining to various Anti-Kickback Statute and Civil Monetary Penalties Law new regulations and modifications (“Proposed Rule”). The Proposed Rule is one component of the Department of Health and Human Services’s (“HHS’s”) recently launched “Regulatory Sprint to Coordinated…Read More

With the October 1, 2019 beginning date now past for Patient Driven Payment Model (“PDPM”), the new skilled nursing case-mix classification mode under the Skilled Nursing Facility Prospective Payment System (“SNF PPS”) for classifying SNF patients in a covered Medicare Part A stay, providers need to consider several key legal and compliance program considerations that…Read More

On September 30, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published notice of a proposed survey (“Survey”) of drug acquisition costs for all hospitals participating in the 340B drug discount program (“340B Program”). The Survey would require reporting of acquisition cost data on 340B discounted drugs, referred to as specified covered outpatient drugs…Read More

On October 2, 2019, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that a Texas dental practice (“Practice”) will settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) by paying a civil penalty of $10,000 and adopting a corrective action plan. A patient of the…Read More