Julie Kass

Julie Kass

Ober|Kaler

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CMS Re-proposes Ban on Per-Click Fees for Space and Equipment Leases under Stark

In the CY 2017 Medicare Physician Fee Schedule (CY 2017 MPFS), the Centers for Medicare & Medicaid Services (CMS) issued proposed updates to the physician self-referral law (Stark law). The primary Stark law update focused on...more

8/15/2016 - CMS Commercial Leases Equipment Lease Fraud and Abuse GAO Health Care Providers Inpatient Prospective Payment System (IPPS) Medicare MPFS OIG Physicians Proposed Rules Provider Payments Public Comment Secretary of HHS Stark Law

Specialty Pharmacy Per-fill Fee Rejected by OIG

On August 15, 2014, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued a “negative” opinion regarding a specialty pharmacy’s proposal to pay a per-fill fee to local pharmacies for support...more

9/4/2014 - Anti-Kickback Statute Fraud and Abuse HHS OIG Patient Referrals Pharmacies Prescription Drugs

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 (FCA) Health Insurance Exchanges Healthcare Healthcare Reform HHS OIG Premiums Qualified Health Plans

OIG Updates Special Advisory Bulletin on the Effect of Exclusion from Federal Health Programs

On May 8, 2013, the OIG issued an update that supersedes and replaces its 1999 Special Advisory Bulletin, The Effect of Exclusion from Participation in Federal Health Care Programs. The updated bulletin continues to stress...more

5/14/2013 - Databases Exclusions Health Insurance Healthcare OIG Payment Plans

OIG Calls PODs "Inherently Suspect"

Making its most strongly worded statement to date, the Department of Health and Human Services Office of Inspector General (OIG) issued a Special Fraud Alert on Physician-Owned Entities on March 26, 2013, calling...more

3/29/2013 - Ambulatory Surgery Centers Anti-Kickback Statute Client Referrals Fraud Healthcare Hospitals Joint Venture Manufacturers Medical Devices OIG Physician-Owned Distributors Physicians

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