Hannah Whitman Clark

Hannah Whitman Clark

Ober|Kaler

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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

CMS Publishes Proposed 2015 OPPS and ASC Payment Rule

On July 3, 2014, CMS posted the proposed CY 2015 outpatient perspective payment system (OPPS) and Ambulatory Surgical Center (ASC) payment rule, which was subsequently published in the Federal Register on July 14, 2014 [PDF]....more

7/25/2014 - CMS Healthcare Healthcare Facilities Hospitals OPPS Reimbursements Rulemaking Process

AMA Issues Telemedicine Guidelines

On June 11, 2014, the American Medical Association (AMA) released a new set of telemedicine principles, which emerged from its policy report addressing “Coverage and Payment for Telemedicine.” The AMA report details the...more

7/15/2014 - American Medical Association CMS Healthcare Reimbursements Telemedicine

CMS Issues Cost Savings Reforms to Medicare Regulatory Requirements

On May 12, 2014, CMS issued a final rule, reforming certain Medicare regulatory requirements and eliminating those identified as unnecessary, obsolete, or excessively burdensome. Many of the streamlined provisions relate to...more

6/12/2014 - CMS Healthcare Healthcare Reform Hospitals Medicare Terms and Conditions

Medicare Proposes Prior Authorization Process for Certain DMEPOS Items

On May 28, 2014, CMS issued a proposed rule to establish a permanent prior authorization process for certain durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) items that are “frequently subject to...more

6/9/2014 - CMS DMEPOS Enforcement Healthcare Medicare Prior Authorization Proposed Regulation

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

6/2/2014

Highlights of Proposed Rules for Skilled Nursing Facilities, Inpatient Rehabilitation Facilities, and Inpatient Psychiatric...

On May 1, 2014, CMS released proposed payment and policy changes for Medicare Skilled Nursing Facilities (SNFs), Inpatient Rehabilitation Facilities (IRFs), and Inpatient Psychiatric Facilities (IPFs). Some of the key changes...more

5/21/2014 - CMS Healthcare Inpatient Rehab Facilities IRF Claim Processing Payment Systems Proposed Regulation Public Comment SNF

Highlights of the Protecting Access to Medicare Act of 2014

On the first of this month, President Obama signed into law the Protecting Access to Medicare Act of 2014. The measure extends a multitude of provisions that were set to expire and also incorporates many provisions that may...more

4/28/2014 - Healthcare Healthcare Reform Medicare Protecting Access to Medicare Act

Maryland Health Care Commission Proposes to Extend and Revise EHR Incentive Regulations

On March 21, 2014, the Maryland Health Care Commission (MHCC) published proposed revisions to the existing Maryland Electronic Health Record Incentives regulations at COMAR 10.25.16. The proposed regulations [PDF] would...more

4/25/2014 - CMS EHR Healthcare Incentives Physician Payments

HIPAA Security Risk Analyses

As noted in Paul Kim and Hannah Whitman Clark's article regarding HIPAA Security Risk Analyses, CEs and BAs are required to review and update their risk assessments only under certain conditions after completing their initial...more

4/1/2014 - Data Protection HIPAA PHI Risk Assessment

Security Rule Compliance: The Importance of Performing Regular Risk Analyses

It is likely that you are familiar with the HIPAA Security Rule’s mandate that covered entities and business associates document the decision making process that led to the selection of their means to achieve security for...more

4/1/2014 - Data Breach Data Protection ERISA PHI Risk Assessment

Chance to Comment on Future of DMEPOS Payments

CMS recently took the unusual step of issuing an Advance Notice of Proposed Rulemaking (ANPR) regarding changes to Medicare payment methodologies for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS)...more

3/26/2014 - Affordable Care Act CMS Competitive Bidding Durable Medical Equipment Healthcare Medical Devices Medicare

OIG Approves Medigap Policy Contracts with Preferred Hospital Networks

On February 20, the U.S. Department of Health & Human Services, Office of the Inspector General (OIG) released Advisory Opinion 14-02, concerning the use of preferred hospital networks as part of certain Medicare Supplemental...more

2/28/2014 - Advisory Opinions Anti-Kickback Statute Civil Monetary Penalty Healthcare Hospitals Medicare Medicare Part A Medigap OIG Safe Harbors

CMS Provides Clarification Regarding HHA Face-to-Face Documentation

In January 2014, CMS released a Special Edition Article of MLN Matters to clarify the documentation requirements for Home Health Prospective Payment System (HH PPS) Face-to-Face Encounters. CMS found that insufficient...more

2/20/2014 - CMS Healthcare Home Health Care Required Documentation

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

CMS Seeks Comments on Establishment of CMPs Related to MSP Reporting

CMS recently solicited comments for the development of methodologies and criteria to be used in evaluating whether or not to impose civil money penalties (CMPs) on arrangements of certain group health plans (GHPs) and...more

1/27/2014 - Benefit Plan Sponsors Civil Monetary Penalty CMS Employee Benefits Employer Group Health Plans Healthcare Medicare Medicare Secondary Payer Act

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