Christopher P. Dean

Christopher P. Dean


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Will Physicians Accept CMS's Offer to "Pick Your Pace"?

The Acting CMS Administrator, Andy Slavitt, announced that CMS would propose new options for physician participation in the Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)....more

9/19/2016 - CHIP CMS Medicare Medicare Access and CHIP Reauthorization (MACRA) Physicians Provider Payments Quality Payment Program (QPP)

Health Care Legislation Maryland 2016 First Interim Report

The bills cited and reviewed in this Report are not an exhaustive presentation of all healthcare legislation. Rather, they represent either proposed or adopted legislation that we believe are among the most beneficial,...more

8/30/2016 - Acupuncture Chiropractors End-of-Life-Care FTC Health Care Providers Hospitals Medical License Medical Marijuana Medical Records Mergers New Legislation Nurses Physical Therapists Physicians Prescription Drugs Public Information Reciprocity Rules

Summary of Major Provisions in the Proposed 2017 Physician Fee Schedule

The proposed Physician Fee Schedule for 2017 (PFS) includes several changes covering a litany of topics spanning from telehealth services to expanding the Diabetes Prevention Program Model. The following is a high-level...more

7/22/2016 - CMS Medicare Access and CHIP Reauthorization (MACRA) Medicare Advantage Medicare Shared Savings Program Physician Fee Schedule Public Comment Self-Referral Telehealth

OIG Approves Wholly Owned Group Purchasing Organization

In Advisory Opinion 16-06, the Office of Inspector General (OIG) approved a proposal whereby the ownership of a group purchasing organization (GPO) would be restructured so that the GPO will be wholly owned by the same...more

6/6/2016 - Anti-Kickback Statute Fraud and Abuse GPOs Health Care Providers OIG Parent Corporation Subsidiaries

Physician Payment: CMS Proposes Quality Payment Program, Advanced APMs, and Merit-Based Incentive Payment System

CMS published its 426 page proposed rule on the Quality Payment Program (QPP) – the successor to oft-maligned Sustainable Growth Rate adjustment – on May 9, 2016. The QPP will adjust physician and mid-level provider...more

5/16/2016 - Alternative Payment Models (APM) CMS MIPS Physician Payments

Comprehensive Primary Care Plus Model: Today's Alternative Payment Model for Primary Care Providers Could Be Tomorrow's Obligatory...

In an effort to affect how approximately 25 million Medicare beneficiaries and other commercial insurance patients receive primary care services, the CMS Innovation Center (the "Innovation Center") announced the Comprehensive...more

5/2/2016 - Beneficiaries CMS Comprehensive Primary Care (CPC+) Medical Reimbursement Medicare Physician Payments Provider Payments

OIG Approves Hospital-provided Transcription Services Arrangement in Advisory Opinion 15-15

The Office of Inspector General (OIG) recently issued Advisory Opinion 15-15 and concluded that an arrangement under which a hospital proposed to provide transcription services to a radiology practice in exchange for fair...more

2/16/2016 - Advisory Opinions Anti-Kickback Statute CMS Diagnostic Imaging Services Fair Market Value Hospitals OIG Patient Referrals

Physician Payment: CMS Seeks Suggestions for SGR, PQRS, Meaningful Use and VBM Replacement

CMS would like your help in developing the replacement to the Sustainable Growth Rate adjustment (SGR). But you need to act quickly because CMS' cutoff date for your suggestions is October 31, 2015....more

10/16/2015 - CHIP CMS Meaningful Use Medicare Medicare Access and CHIP Reauthorization (MACRA) MIPS Notice and Comment Physician Payments PQRS Request For Information Sustainable Growth Rate (SGR) Value-Based Payments

King v. Burwell: An Interchangeable Exchange

The Supreme Court ruled recently in favor of the Obama Administration and its defense of another provision of the Patient Protection and Affordable Care Act (ACA or the Act). King v. Burwell, No. 14-114 (U.S. June 25, 2015)....more

8/19/2015 - Affordable Care Act Chevron Deference Federal Health Insurance Exchanges Health Insurance Exchanges Individual Mandate King v Burwell Medicaid SCOTUS Spending Clause State Health Insurance Exchanges Tax Credits

OIG Approves Another Medigap-Preferred Hospital Networks Arrangement

The U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-09 [PDF] on July 16, 2015, once again approving Medicare Supplemental Health Insurance (Medigap) insurers indirect...more

8/14/2015 - HHS Hospitals Medigap OIG Preferred Hospital Networks Arrangement

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

It's Time to Bill Medicare: Do You Know Where Your Physicians Are?

The Department of Health and Human Services Office of Inspector General (OIG) recently reported that Medicare contractors overpaid physicians $33.4 million in incorrectly coded physician services between January 2010 and...more

6/29/2015 - Healthcare Medicare OIG Physician Medicare Reimbursements Physicians

MIPS: Moving Physician Payments Beyond the Sustainable Growth Rate?

Medicare continues to transition its primary physician payment methodology from a traditional fee-for-service model into a quality and value-based model. Recently, the Medicare Access and CHIP Reauthorization Act of 2015...more

5/29/2015 - CHIP CMS Medicare Medicare Access and CHIP Reauthorization (MACRA) Merit-Based Point System MIPS Physician SGR Formula Physicians Sustainable Growth Rate (SGR)

Medigap Deductible Discount Proposal Approved by OIG

The Office of Inspector General (OIG) recently issued Advisory Opinion 15-03 and concluded that a licensed provider (the Requestor) of Medicare Supplemental Health Insurance (Medigap) would not be sanctioned under the civil...more

4/1/2015 - Anti-Kickback Statute CMP Law Hospitals Medicare Medicare Part A Medigap OIG

No Sanctions for Basic Life Support Service Provider

The Office of Inspector General (OIG) recently issued Advisory Opinion 14-09 [PDF] and concluded that a town that uses tax revenues to cover out-of-pocket expenses owed for basic life support (BLS) emergency ambulance...more

11/25/2014 - Advisory Opinions Ambulance Providers Anti-Kickback Statute CMP Law Cost-Sharing HHS OIG Tax Revenues

Veterans Access, Choice, and Accountability Act May Result in More Patients for Medicare Providers

The President signed the Veterans Access, Choice, and Accountability Act of 2014 [PDF] on August 7, 2014 (the “Act”). Ordinarily, the Department of Veterans Affairs (VA) provides medical care to veterans at Veterans Health...more

8/25/2014 - Department of Veterans Affairs Healthcare Medicare Veterans Veterans Administration VEVRAA

Jury Verdict Against Millennium Provides Insight on Definition of Remuneration

Ameritox won the latest volley of an ongoing legal battle with Millennium when a federal jury in Florida awarded it $14.75 million on June 16, 2014. Ameritox persuaded the jury that Millennium’s free point of care test (POCT)...more

7/9/2014 - Anti-Kickback Statute Kickbacks Medicaid Medicare Remuneration Stark Law

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 Proposes Enhanced Role for Non-Physician Practitioners in Rural Health Clinics

Recognizing the difficulty many rural health clinics (RHCs) face when recruiting health care practitioners, CMS recently proposed to change its interpretation of the Rural Health Clinic Services Act and allow RHCs to contract...more

11/7/2013 - CMS Healthcare Independent Contractors Medicare Rural Health Care Providers

OIG Not Asleep at the Switch: Reviews Polysomnography Services from 2011

The OIG recently released its review of polysomnography services (sleep studies) provided in both hospital-based outpatient settings and non-hospital settings. Medicare pays for sleep studies to diagnose obstructive sleep...more

10/28/2013 - Medical Research Medicare OIG

CMS Proposes FQHC Prospective Payment System

On September 23, 2013, CMS published a proposed rule to overhaul the payment methodology for federally qualified health centers (FQHCs). The proposed rule will change FQHC reimbursement from an all inclusive rate (AIR),...more

10/18/2013 - Affordable Care Act CMS FQHC Healthcare Payment Plans

CMS Expands MSP Recovery Portal

Earlier in 2013 the President signed into law the Strengthening Medicare and Repaying Taxpayers Act of 2012 (the “Smart Act”) requiring CMS to establish a web portal for beneficiaries, their attorneys, and authorized...more

10/4/2013 - CMS Medicare Medicare Secondary Payer Act

Complex Chronic Care Management Reimbursement for 2015 Included in Proposed 2014 Physician Fee Schedule

The proposed 2014 Medicare Physician Fee Schedule [PDF] included reimbursement for case management to be made available in 2015 for physicians who treat patients with two or more complex conditions. The proposed rule would...more

7/25/2013 - CMS Electronic Medical Records Healthcare Home Health Care Medicare Physician Medicare Reimbursements Physician Payments Physicians

OIG Self-Disclosure Protocol 2.0: Evolution Continues with Online Application

The OIG continued its Self-Disclosure Protocol (SDP) evolution this year when it announced that its voluntary SDP application was available online at the Self-Disclosure Protocol home page. The new online application is the...more

7/22/2013 - Compliance Enforcement OIG Policy Violations Provider Self-Disclosure Protocol

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