Catherine Martin

Catherine Martin


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Key Ingredients of CMS' Proposed Comprehensive Care for Joint Replacement Model

On July 14, 2015, CMS released a proposed rule regarding a new, alternative payment model: the Comprehensive Care for Joint Replacement (CCJR) program. Modeled in large part on the Bundled Payments for Care Improvement (BPCI)...more

8/3/2015 - Alternative Payment Models (APM) BPCI Bundled Payments CCJR CMS Hospitals Medicare

Stark Regulations: Proposed Physician Recruitment Provisions

Assistance to Employ a Non-Physician Practitioner (NPP) - Currently under the Stark law, the physician recruitment exception (42 C.F.R. § 411.357(e)) permits hospitals, Federally Qualified Health Centers (FQHCs) and...more

7/23/2015 - CMS FQHC Hospitals Physician Recruitment Agreement Physicians Recruitment Policies Remuneration Rural Health Care Providers Stark Law

Medicare Access and CHIP Reauthorization Act: Paving the Way for Broader Gainsharing Activities

On April 16, 2015, President Obama signed into law H.R.2, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), a critical piece of health care legislation which represents significant movement towards a health...more

4/28/2015 - CHIP Civil Monetary Penalty Gainsharing HHS Hospitals Medicare Medicare Access and CHIP Reauthorization (MACRA) OIG Physicians

Highlights of OIG's Proposal to Amend Safe Harbors to the Antikickback Statute and CMP Rules, and to Add New Safe Harbors

On October 3, 2014, the Department of Health and Human Services Office of Inspector General (OIG) issued a proposed rule to establish new safe harbors under the antikickback statute and the civil monetary penalty (CMP) rules,...more

10/16/2014 - Affordable Care Act Ambulance Providers Anti-Kickback Statute CMP Law Cost-Sharing Medicare Modernization Act OIG Pharmacies Proposed Regulation Safe Harbors

Maryland Waiver Hospitals Subject to New Reporting Requirements for Present on Admission Indicators

Maryland waiver hospitals (those operating under section 1814(b)(3) of the Social Security Act (SSA)) are no longer exempt from present on admission (POA) reporting. CMS Transmittal R1380OTN (Change Request 8709) notifies...more


Comments Due for New Expedited Review Process for CMS's Voluntary Self-Referral Disclosure Protocol (SRDP)

The creation of the SRDP through the Affordable Care Act as a mechanism to resolve potential Stark violations was welcomed by the industry. However, since enactment of the regulations implementing the SRDP in 2010, the volume...more

5/29/2014 - Affordable Care Act CMS Healthcare Self-Reporting Stark Law Voluntary Disclosure

Premium Credits Offered to Medigap Policyholders Okayed by OIG

The OIG has approved a licensed insurance broker’s proposal to establish a preferred hospital network as part of Medicare Supplemental Health Insurance policies (Medigap) and related premium credit offered to policy holders....more

4/24/2014 - Advisory Opinions Healthcare Hospitals Medigap OIG

OIG Revisits Clinical Laboratory Electronic Data Transmission Fees

Prior Opinion Rescinded and Negative Opinion Issued - The Office of Inspector General (OIG) recently issued a negative advisory opinion about an arrangement that offered relief of a $1 electronic data transmission fee...more

4/24/2014 - Advisory Opinions EHR Electronic Data Transmissions Fees Healthcare OIG Physicians

CMS Self-referral Disclosure Protocol: 2013 Update and Summary of Settlements

The CMS Self-referral Disclosure Protocol – Background - Under delegated authority, the Centers for Medicare and Medicaid Services (CMS) released its Self-Referral Disclosure Protocol (SRDP) on September 23, 2010, with...more

1/30/2014 - CMS Healthcare Medicaid Medicare Patient Self-Referral Social Security Act Stark Law

Foundations in Fraud and Abuse: Building Blocks of Health Law

The Ober|Kaler Health Care General Counsel Institute is pleased to introduce its Foundations series, a collection of programs designed to equip in-house counsel with a solid foundation in the cornerstones of health law. The...more

7/24/2013 - Anti-Abuse Rule Career Development Compliance Enforcement Fraud Healthcare OIG Self-Reporting

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