Howard Young

Howard Young

Morgan Lewis

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OIG Proposes Rules on Free Transportation, Hospital Gainsharing, and Other Access to Care Arrangements

The proposed rule to give providers more protections to promote beneficiary access to care solicits significant industry input. On October 2, the Department of Health and Human Services (HHS) Office of Inspector...more

10/6/2014 - Affordable Care Act Anti-Kickback Statute Civil Monetary Penalty Gainsharing Health Care Providers Health Insurance Healthcare Hospitals OIG Proposed Regulation Safe Harbors

CMS Issues Warning on Medicare Part D Billing for Hospice Patients

Hospices will be expected to be more vigilant in their decisions to cover and pay for prescription medications covered under their Medicare hospice per diem payment. On December 6, the Centers for Medicare & Medicaid...more

12/11/2013 - CMS Healthcare Hospice Medicare Medicare Part D

CMS Rule Complicates Long-Term Care Facility and Hospice Relationships

Final rule aims to improve the quality and consistency of care between long-term care facilities and hospice providers but may increase conflict between facility and provider staff. ...more

7/1/2013 - CMS Compliance Final Rules Healthcare Hospice Long-Term Care Medicaid Medicare New Legislation

OIG Revises Special Advisory Bulletin on Exclusions

OIG continues its aggressive interpretation of scope and effect of exclusion from participation in Federal health care programs and clarifies several open questions....more

5/10/2013 - Affordable Care Act Civil Monetary Penalty CMS Exclusions Health Plan Sponsors Healthcare OIG Payment Plans

HHS OIG Issues Report on Hospice General Inpatient Care Billing

Report makes no formal recommendations, but OIG notes that lengths of stay and frequency of general inpatient care are issues requiring further scrutiny....more

5/9/2013 - Billing HHS Hospice Medicare OIG

CMS Aims to Grease the Reporting Wheels for Medicare Fraud and Abuse

Proposed rule would substantially increase rewards for fraud tips and enhance billing revocation authority. On April 29, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule (Proposed Rule) that...more

4/30/2013 - CMS Fraud and Abuse Incentive Awards Medicare Proposed Regulation

HHS OIG Issues Revised Self-Disclosure Protocol

OIG touts substantial benefits of disclosing, provides greater detail for different types of disclosures, and captures 15 years of OIG Self-Disclosure Protocol experience....more

4/18/2013 - Anti-Kickback Statute Damages HHS OIG Self-Disclosure Requirements Stark Law

Protections to Be Extended for Electronic Health Record Donations

CMS and OIG issue similar proposed rules to modify the electronic health record exception and safe harbor. On April 10, the Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) of...more

4/17/2013 - CMS EHR Final Rules OIG Proposed Amendments Safe Harbors

OCR Reaches $50,000 Settlement with Hospice for Small Data Breach

Enforcement action sends a strong message to the healthcare industry and reaffirms the need for security risk analysis and mobile-device security policies and procedures....more

1/8/2013 - Data Breach Data Protection Electronic Medical Records HIPAA HITECH HONI Mobile Devices OCR PHI Settlement

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