Hannah Whitman Clark

Hannah Whitman Clark

Ober|Kaler

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Final FY 2017 Inpatient Psychiatric Facilities Payment and Policies Rule, Payment Matters

On August 1, 2016, CMS published the FY 2017 Inpatient Psychiatric Facilities (IPF) Prospective Payment System (PPS) – Rate Update notice. Some of the key changes are highlighted below....more

8/22/2016 - CBSA CMS Inpatient Prospective Payment System (IPPS) OMB Psychiatric Hospitals Wage Index

OIG Approves Hospice Payments to Nursing Facility for Dual Eligible Patients Under Medicaid Demonstration Project

On July 20, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued a favorable Advisory Opinion (16-08) [PDF] regarding payments from a hospice to a nursing facility in which a dual...more

8/12/2016 - Dual Eligibility Hospice Medicaid OIG Patients Provider Payments Skilled Nursing Facility

CMS Releases the 2016 OPPS Proposed Rule

On July 15, CMS published its proposed policy changes, quality provisions, and payment rates for 2017 as they relate to the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC)...more

7/25/2016 - Ambulatory Surgery Centers CMS EHR Electronic Health Record Incentives OPPS Proposed Rules Value-Based Purchasing

OCR Clarifies Parameters of Covered Entities' Fees for PHI Copies

The Office for Civil Rights (OCR) recently released new guidance and FAQs (OCR Guidance) addressing individuals’ rights to access their protected health information (PHI) under the Health Insurance Portability and...more

6/8/2016 - Covered Entities EHR Federal v State Law Application Fees HIPAA Patient Rights PHI Preemption

Proposed Changes to the Part 2 Regulations: Another Example of Necessary Flexibility in the Wake of Changes to Health Care...

On February 9, 2016, the Substance Abuse and Mental Health Services Administration (SAMHSA) published a proposed rule to update and modernize the Confidentiality of Alcohol and Drug Abuse Patient Records regulations governing...more

4/14/2016 - Confidential Documents Drug & Alcohol Abuse Mental Health Patient Privacy Rights Privacy Policy SAMHSA

Wage Index Reclassification Rule Struck Down by Second Circuit

On February 4, 2016, the United States Court of Appeals for the Second Circuit decided Lawrence + Memorial Hospital v. Burwell. The case addressed a regulation, issued by the Secretary of Health and Human Services...more

3/2/2016 - Chevron Deference Drug Pricing HHS Hospitals Medicare Reclassification Rules Rural Health Care Providers Wage Index

OIG Approves Charitable Program Providing Financial Assistance for MRIs in Advisory Opinion 15-14

On November 13, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-14. The Arrangement at issue is a charitable program designed to assist financially needy...more

2/17/2016 - Advisory Opinions Anti-Kickback Statute Charitable Organizations Civil Monetary Penalty Inducements Medicaid Medicare MRI OIG Patient Assistance Programs

OIG Issues (Another) Favorable Advisory Opinion Regarding Medigap/Preferred Hospital Network Arrangement in Advisory Opinion 16-01

On January 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 16-01, approving yet another insurer’s proposed contract with a preferred hospital network. The...more

2/11/2016 - Advisory Opinions Anti-Kickback Statute Discounts Inducements Medicare Medigap OIG Preferred Hospital Networks Arrangement

Stark Updates Included in Final 2016 Physician Fee Schedule

With the final Medicare physician fee schedule (PFS) for 2016, the Centers for Medicare and Medicaid Services (CMS) has made a series of updates to the Stark physician self-referral regulations. The final rule is largely...more

12/2/2015 - CMS Physician Fee Schedule Physician Recruitment Agreement Physician-Owned Hospitals Stark Law Technical Standards

Uncertainty Continues for Two-Midnight Rule's Payment Reduction

In Shands Jacksonville v. Burwell [PDF], No. CV 14-1477, 2015 WL 5579653, (D.D.C. Sept. 21, 2015), the United States District Court for the District of Columbia gave the Secretary of the Department of Health and Human...more

10/14/2015 - Administrative Procedure Act HHS Hospitals Inpatient Billing Medicare Notice and Comment Provider Payments Rulemaking Process Secretary of HHS Two-Midnight Rule

Open Payments Update: End of CME Exception for Sunshine Reporting

On July 17, 2015, CMS announced updates to the Law and Policy page on the Open Payments website to provide additional guidance regarding the termination of the continuing medical education (CME) exception for reporting under...more

8/17/2015 - CME CMS Medicare Open Payments Reporting Requirements Sunshine Act

Stark Regulations: Proposed Physician-owned Hospitals Provisions

In the proposed Physician Fee Schedule for 2016 [PDF], CMS recommends amending several requirements related to the physician-owned hospital and rural provider exceptions to the Stark law. As discussed more fully below, CMS...more

7/23/2015 - CMS Exceptions Hospitals Patient Referrals Physician Fee Schedule Physician-Owned Hospitals Rural Health Care Providers Stark Law

Again, the OIG Approves a Medigap Policy Contract with Preferred Hospital Networks

On June 12, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-08. This opinion continues the well-established pattern of favorable advisory opinions which...more

7/3/2015 - Anti-Kickback Statute Civil Monetary Penalty Fraud and Abuse Health Insurance HHS Hospitals Medigap OIG Preferred Hospital Networks Arrangement

CMS Pays $1.3 Billion to Hospitals for Settlements of Medicare Inpatient Appeals

On June 11, 2015, CMS announced that it had entered into settlements with over 1,900 hospitals for over 300,000 disputed inpatient billing claims. CMS updated its website dedicated to inpatient hospital reviews, noting that...more

6/27/2015 - CMS Healthcare Hospitals Inpatient Billing Medicare Settlement Agreements

Medicare Shared Savings Program - 2015: What's Changed, What's New, and What's to Come?

The most recent Shared Savings Program final rule, published in the Federal Register on June 9, 2015, finalizes a number of the revisions to the original November 2011 final rule that CMS proposed on December 8, 2014. In...more

6/17/2015 - ACO Participant Agreements ACOs Benchmarks CMS HHS Medicaid Medicare Medicare Shared Savings Program Physician Medicare Reimbursements SNF Waivers

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

Excluded Individual Not Precluded from Payment for Pre-exclusion Services

In Advisory Opinion 15-02 [PDF], issued February 9, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) looked favorably on the Requestor’s inquiry as to whether receipt of Federal health...more

2/28/2015 - Advisory Opinions False Claims Act (FCA) HHS OIG

HHS Identifies Specific Goals to Move Toward Paying for Quality of Care

On January 26, 2015, the U.S. Department of Health and Human Services (HHS) announced a new initiative to shift Medicare reimbursements from volume to value using new payment methodologies for physicians and hospitals. Such a...more

2/9/2015 - Fee-for-Service Healthcare HHS Hospitals Medicare Physician Medicare Reimbursements Quality of Care Standards

Guidance, Not Regulations, Expected for 340B Drug Pricing Program

The long-awaited 340B “mega rule,” promised by the Health Resources and Services Administration (HRSA) to be published last summer, has now been officially nixed. HRSA recently announced that it will not release the...more

12/15/2014 - HRSA New Guidance Prescription Drugs Section 340B

OIG's 2015 Work Plan Highlights Departmental Priorities

Each year the Department of Health and Human Services, Office of the Inspector General (OIG) issues its Work Plan to identify for the provider community the key fraud and abuse issues on which it will focus on in the coming...more

11/24/2014 - Ambulance Providers Ambulatory Surgery Centers CMS Health Care Providers HHS Home Health Agencies Hospice Hospitals Medical Devices Nursing Homes OIG Prescription Drugs Work Plans

Highlights of the 2015 OPPS and ASC Final Rule

On October 31, 2014, CMS published its 2015 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Policy Changes and Payment Rates final rule. This annual rule affects the 4,000...more

11/18/2014 - CMS Final Rules Hospitals OPPS Patient Prospective Payment System

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

OIG Approves Yet Another Medigap Policy Contract with Preferred Hospital Network

On September 17, 2014, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 14-08 [PDF]. This opinion is yet another favorable advisory opinion approving a Medicare...more

10/13/2014 - Anti-Kickback Statute Civil Monetary Penalty Health Insurance Hospitals Medigap OIG Safe Harbors

WEBINAR: Breach, Enforcement and Beyond: HIPAA Breach Notification Analysis and OCR Enforcement Activities

The Office for Civil Rights of the US Department of Health and Human Services revised the breach notification regulations last year in order to make the analysis of whether a breach occurred more objective. In addition, OCR...more

9/18/2014 - Breach Notification Rule Data Breach Data Protection Enforcement Enforcement Actions HHS HIPAA OCR

CMS Retracts Hospice Preauthorization Requirements for Part D Drugs

On July 18, CMS released new guidance retracting a major portion of its controversial preauthorization requirement for hospice beneficiaries. The new guidance supersedes portions of the March 10, 2014 guidance [PDF] that...more

8/8/2014 - CMS Healthcare Hospice Medicare Medicare Part D Prescription Drugs

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