Articles and Blogs

The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently issued Advisory Opinion No. 23-15 (“Advisory Opinion”), a favorable opinion involving a consulting firm’s (“Requestor”) proposal to offer gift cards to its existing physician practice customers for referring potential new customers. The OIG approved the Proposed Arrangement (defined below), noting... READ MORE

In response to COVID-19, the Centers for Medicare & Medicaid Services (“CMS”) has implemented multiple updates to the Merit-Based Incentive Payment System (“MIPS”) to relieve clinicians of certain reporting requirements including an extension for the 2019 performance year data submission deadline and the extension of the MIPS Extreme and Uncontrollable Circumstances policy for individual... READ MORE

CMS recently posted reminders regarding the availability of MIPS final scores and the deadline to request review if an error has been made: “If you participated in the Merit-based Incentive Payment System (MIPS) in 2018, your performance feedback, which includes your MIPS final score and payment adjustment factor(s), are available for review on the Quality... READ MORE

On July 10, 2019, CMS issued proposed rulemaking titled Medicare Program; Specialty Care Models to Improve Quality of Care and Reduce Expenditures. The rule proposes to implement two new mandatory Medicare payment models – the Radiation Oncology Model and the End-Stage Renal Disease (“ESRD”) Treatment Choices Model. Comments on this proposed rule are due... READ MORE