Articles and Blogs

Overview Recently, the Department of Health & Human Services Office of the Inspector General (“OIG”) issued Advisory Opinion 15-06 addressing a 501(c)(3) charitable organization’s proposed arrangement to provide financial assistance to individuals with certain chronic diseases.  Using donated funds, the organization would assist qualifying individuals with health insurance costs, drug/device therapy costs and other incidental…Read More

Now that the summer vacation season is officially upon us, it is important for employers and their nonimmigrant workers to consider the potential risks nonimmigrant workers face when traveling internationally prior to the start date of an approved H-1B petition. According to an informal immigration policy known as the “Last Action Rule,” the last action…Read More

Executive Summary On June 9, 2015, the U.S. Department of Health and Human Services Office of the Inspector General (“OIG”) released a Fraud Alert (the “Alert”) warning that physicians can face significant liability for entering into compensation arrangements that potentially violate the Federal Anti-Kickback Statute (“AKS”).  Specifically, OIG noted that physicians entering compensation arrangements, such…Read More

On June 4, 2015, CMS released for public inspection a final rule that makes significant changes to the regulations governing Medicare Shared Savings Program (“MSSP”) ACOs.  The rule, scheduled to be officially published in the Federal Register on June 9, revises numerous functions related to MSSP ACOs and their operations and codifies previous CMS guidance. …Read More

On June 4 and June 10, the Rural Utilities Service will host webinars focused on the Distance Learning and Telemedicine Grant Program. These webinars will inform participants about the major eligibility and regulatory requirements of the program and provide detailed guidance on how to submit a successful grant application. Click here to learn more. If…Read More

Health care providers and practitioners in most states are well aware that most Medicaid and CHIP enrollees are members of managed care organizations (“MCOs”). As states have increasingly contracted with and relied on MCOs for their growing Medicaid and CHIP populations, including enrollees who need and use long-term care services, the Centers for Medicare &…Read More

Finance Committee Passes Bill Increasing Oversight of Medicare Audit Contractors On June 3, the Senate Finance Committee passed a bill that would increase oversight of Medicare audit contractors and streamline appeals functions to expedite the Medicare appeals process. The measure would require CMS to establish incentives for auditors to ensure accuracy and allow multiple pending appeals…Read More

Take a look at the FMLA forms you are now using and glance at the top right corner where you will see an OMB Control Number.  Just below that number, what does the expiration date say?  A safe bet is that the form you are using has expired!  But, all is not lost as the U….Read More

House Subcommittee Circulates Proposed 340B Legislation The House Energy and Commerce Health Subcommittee recently released draft legislation that seeks to reform the 340B Drug Pricing Program, which requires drug manufacturers to offer drug discounts to eligible hospitals and other facilities for outpatient use. The measure proposes a number of material and cosmetic changes, including formally…Read More

Executive Summary On May 28, 2015, the Office of the Inspector General (“OIG”) published a mid-year update to its Fiscal Year (“FY”) 2015 Work Plan (“Updated Plan”).  The Updated Plan identifies certain new projects that OIG started since, and that did not appear in, the original FY 2015 Work Plan published in October 2014.  OIG has…Read More