Elizabeth Carder-Thompson

Elizabeth Carder-Thompson

Reed Smith

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CMS Posts PAMA Clinical Lab Fee Schedule Data Reporting Template and User Guide

In order to assist the clinical laboratory community in meeting new Medicare reporting requirements under the Protecting Access to Medicare Act of 2014 (PAMA), CMS has posted a Clinical Laboratory Fee Schedule Data Reporting...more

9/13/2016 - CLFS Clinical Laboratories Clinical Laboratory Testing CMS Data Collection Medicare PAMA Reporting Requirements

HHS Inflation Adjustment Rule Hikes CMPs Across Department Programs

The Department of Health and Human Services (HHS) is increasing maximum civil monetary penalty (CMP) amounts applicable to HHS agencies and programs, in compliance with the Federal Civil Penalties Inflation Adjustment Act...more

9/8/2016 - Bipartisan Budget Act Civil Monetary Penalty DOJ False Claims Act (FCA) Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 HHS Inflation Adjustments Penalties

Game-Changing PAMA Rule Sets off Major Payment Shifts for Lab Tests

The Centers for Medicare & Medicaid Services (CMS) recently published a major final rule that will base Medicare clinical laboratory fee schedule (CLFS) reimbursement on private insurance payment amounts, as required by the...more

8/16/2016 - ADLT CEOs Certifications CFOs Civil Monetary Penalty CLFS Clinical Laboratories Clinical Laboratory Testing CMS Data Collection Final Rules Health Insurance Medicare PAMA Payment Methods Reporting Requirements

CMS Proposes Sweeping 'Episode Payment Models' for Cardiac Care, Hip/Femur Fracture Cases, Plus Changes to 'Comprehensive Care for...

Proposed Rule to Impact Hundreds of Hospitals and Post-Acute Providers - Building on the current mandatory Comprehensive Care for Joint Replacement (CJR) bundled payment initiative, the Centers for Medicare & Medicaid...more

8/12/2016 - Alternative Payment Models (APM) Bundled Payments CCJR CMS Comment Period Episode Payment Models (EPM) Fee-for-Service Health Care Providers Hospitals Performance Period Proposed Regulation Reconciliation Suppliers

OIG, CMS Focus New Scrutiny on Home Health Industry: Additional Investigative and Enforcement Activity Likely to Follow

On June 22, 2016, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a comprehensive report detailing its nationwide analysis of common characteristics in home health fraud cases. In tandem...more

7/7/2016 - Analytics CMS Fraud Abuse and Waste Fraud Alerts Healthcare Fraud Home Health Agencies Home Health Care Medicare OIG Physicians

Physician-Owned Distributor (POD) Update

For some time, we have been reporting on issues involving federal government scrutiny of physician-owned distributors ("PODs"). From the Department of Health and Human Services Office of Inspector General’s ("OIG") issuance...more

5/17/2016 - Anti-Kickback Statute Congressional Reports DOJ Fraud Alerts OIG Physician-Owned Distributors Physician-Owned Hospitals Physicians Senate Finance Committee Stark Law Sunshine Act

CMS Proposes Testing Medicare Part B Drug Payment Reforms to Promote Value

CMS has released a complex and controversial plan – the Part B Drug Payment Model — to test new Medicare payment methods for certain Part B drugs to determine whether alternative payment designs will reduce Medicare...more

3/26/2016 - Alternative Payment Models (APM) Biologics CMS Comment Period Medicare Part B Prescription Drugs Proposed Regulation Value-Based Purchasing

Another Day, Another Whistleblower Retaliation Suit

A False Claims Act (“FCA”) retaliation claim, 31 U.S.C. 3730(h), filed January 26, 2016 in federal district court in Oregon, provides a perfect example of the type of challenging cases confronting health care employers today....more

1/28/2016 - Anti-Kickback Statute False Claims Act (FCA) Overpayment Policies and Procedures Retaliation Stark Law Termination Whistleblowers

Medicare Launches Its First Mandatory Bundled Payment Model for Joint Replacement Care – What You Need to Know to Get Ready

On November 24, 2015, the Centers for Medicare & Medicaid Services (CMS) published a significant final rule that will require hospitals in selected geographic areas to participate in a new Medicare Comprehensive Care for...more

12/18/2015 - BPCI Bundled Payments CCJR CMS Hospitals Medicare

CMS Finalizes “Comprehensive Care for Joint Replacement” Model

On November 16, 2015, CMS released its final rule to establish a Medicare Comprehensive Care for Joint Replacement (CJR) model that will test whether bundled payments to acute care hospitals for lower extremity joint...more

11/17/2015 - Bundled Payments CCJR CMS Final Rules Hospitals Medicare

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 Health Care Providers Healthcare 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 Industry 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 Industry Physicians Sunshine Act

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