Julie Kass

Julie Kass

Ober|Kaler

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Dodging the AKS: Marketplace Plans Are Not "Federal Health Care Programs"

In an October 30th letter addressed to Congressman Jim McDermott, the Department of Health and Human Services (HHS) Secretary, Kathleen Sebelius, left little to interpretation: Qualified health plans (QHPs) purchased through...more

11/8/2013 - Affordable Care Act Anti-Kickback Statute CMS False Claims Act Health Insurance Exchanges Healthcare Healthcare Reform HHS OIG Premiums Qualified Health Plans

Recent CMS Guidance Partially Lifts Veil on Stark Self-referral Disclosure Protocol

In 2012, the Centers for Medicare and Medicaid (CMS) issued much-anticipated guidance on the Self-Referral Disclosure Protocol (SRDP) through its publication of thirteen settlements and its statutorily-mandated “Report to...more

1/30/2013 - Affordable Care Act CMS Disclosure Requirements Medicaid Medicare Self-Referral Disclosure Protocol Stark Law

CMS Acknowledges Transitional Care Management as Separate Service from E/M

Recognizing that care coordination is a key component to achieving better care and health for individuals and reducing expenditure growth, CMS has implemented several new programs to provide payment for such services,...more

1/18/2013 - CMS Transitional Care Management

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