Elizabeth Carder-Thompson

Elizabeth Carder-Thompson

Reed Smith

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CMS Finalizes Medicare Hospice Wage Index/Rates for FY 2016

On August 6, 2015, CMS is publishing its final rule to update Medicare hospice payment rates and the wage index for fiscal year (FY) 2016. CMS estimates that the final rule will increase overall payments to hospices by about...more

8/5/2015 - CMS Final Rules Hospice IMPACT Act Medicare Nurses Skilled Nursing Facility Wage Index

The Implications of CMS' Proposed Stark Law Regulations

On July 8, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released proposed regulations “to reduce burden and to facilitate compliance” under the physician self-referral law known as the Stark Law. See 80 Fed....more

7/28/2015 - Affordable Care Act Comment Period FQHC Healthcare Healthcare Providers Healthcare Reform Hospitals Nurse Practitioners Patient Referrals Physician Compensation Arrangements Physician Fee Schedule Physician-Owned Hospitals Physicians Proposed Regulation Rural Health Care Providers Self-Referral Stark Law

CMS Proposes “Comprehensive Care for Joint Replacement” Model; Would Mandate Bundled Acute/Post-Acute Medicare Payment in 75 MSAs,...

On July 14, 2015, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule to establish a Medicare Comprehensive Care for Joint Replacement (CCJR) model. Under the proposed rule, CMS would provide a...more

7/23/2015 - Alternative Payment Models (APM) Beneficiaries BPCI CMS Comment Period Fee-for-Service Gainsharing Hospitals Medicaid Medicare Proposed Regulation Waivers

An Apple a Day Keeps the OIG Away: Practical Guidelines for Structuring Physician Compensation Arrangements to Avoid Kickback...

On June 9, 2015, the Office of the Inspector General of the Department of Health and Human Services (OIG) released a fraud alert warning physicians to scrutinize carefully the conditions and terms of any medical director or...more

6/16/2015 - Anti-Kickback Statute CMS Director Compensation Health Care Providers OIG

OIG Partners with Industry Associations by Issuing Practical Guidance for Health Care Governing Boards on Compliance Oversight

On April 20, 2015, the Office of the Inspector General of the Department of Health and Human Services (“OIG”) released educational guidance designed to assist governing boards of health care organizations (“Boards”) in their...more

4/23/2015 - Chief Compliance Officers Corporate Governance Health Care Providers Hospitals New Guidance OIG

President Signs MACRA: Permanently Reforms Medicare Physician Reimbursement Framework, Includes Other Medicare Payment, Program...

On April 16, 2015” (MACRA), which reforms Medicare payment policy for physician services and adopts a series of policy changes affecting a wide range of providers and suppliers. Most notably, MACRA permanently repeals...more

4/17/2015 - CHIP CMS Healthcare Medicaid Medicare Physician SGR Formula Physicians Repeal

Analysis of HHS OIG Proposed Rule to Amend the Anti-Kickback Safe Harbors, CMP Rules on Beneficiary Inducements & Gainsharing...

On October 3, 2014, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) published a major proposed rule that would amend the safe harbors to the Anti-Kickback Statute (AKS) and the Civil...more

10/22/2014 - Affordable Care Act Ambulance Providers Anti-Kickback Statute CMP Law Gainsharing Hospitals OIG Pharmacies Physicians Proposed Regulation Public Comment Rulemaking Process Safe Harbors

HHS OIG Proposes Rule to Expand Exclusion Authorities

On May 9, 2014, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) published a proposed rule that would significantly expand the exclusion regulations applicable to persons or entities...more

5/19/2014 - Administrative Authority Affordable Care Act Exclusions Healthcare HHS Hospitals OIG Proposed Regulation Provider Payments Statute of Limitations

Overview of Primary Provisions of U.S. and French Sunshine Reporting Requirements

2013 was a year of unprecedented scrutiny of financial relationships between manufacturers and health care professionals, such as physicians. Both the United States and France imposed sweeping new reporting and disclosure...more

4/14/2014 - Conflicts of Interest Disclosure Requirements Healthcare Manufacturers Penalties Pharmaceutical Manufacturers Sunshine Act Transparency

The Sunshine Physician Payment Final Rule Overview and Analysis

On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) of the Department of Health and Human Services (HHS) released the long-awaited Final Rule (Rule) to implement the “Sunshine” provisions of the Affordable...more

3/6/2013 - Affordable Care Act CMS Healthcare HHS Manufacturers Medical Devices Pharmaceutical Physicians Sunshine Act

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