Articles and Blogs

The U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) has issued a meaningful Request for Information (“RFI”) seeking stakeholder input on potential new or modified Anti-Kickback Statute (“AKS”) regulatory safe harbors and Beneficiary Inducements Civil Monetary Penalty (“CMP”) exceptions for remuneration to clinical trial participants. The RFI was published... READ MORE

As nursing homes look for funds to allow them to improve care and train nursing home staff, Centers for Medicare & Medicaid Services (“CMS”) released QSO-23-23-NH (“CMS Memo”), which reopens and recasts the Civil Money Penalty Reinvestment Program (“CMPRP”). A Civil Monetary Penalty (“CMP”) is a fine that CMS may impose against nursing homes... READ MORE

The Centers for Medicare and Medicaid Services (“CMS”) recently imposed financial penalties for the first time against two hospitals for failure to comply with the Hospital Price Transparency Rule requirements. According to the Notices of Imposition of Civil Monetary Penalty (“Notices”), which CMS posts on its website, the two hospitals were fined over $1,000,000... READ MORE

Pursuant to Section 6111 of the Affordable Care Act enacted on March 23, 2010, and the final rule published on March 18, 2011 in the Federal Register, a nursing facility must be offered the opportunity to request an Independent Informal Dispute Resolution (IIDR) if the Centers for Medicare & Medicaid Services (CMS) imposes a... READ MORE