Robert G. Homchick

Robert G. Homchick

Davis Wright Tremaine LLP

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Touching Up that Old Two Step: CMS Proposes Revisions to its Beneficiary Assignment Methodology

On Dec. 1, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses...more

12/24/2014 - ACOs CMS Healthcare Medicare Shared Savings Program Proposed Regulation

Changing Basic Rules of the Game: CMS Proposed Rule Relating to ACO Governance and Contracting

The Centers for Medicare and Medicaid Services released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory expands upon our initial...more

12/19/2014 - ACOs CMS Healthcare Medicare Shared Savings Program Proposed Regulation

Keeping Track of the Tracks: Proposed ACO Regulations Alter MSSP Financial Models

Last week, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses on...more

12/12/2014 - ACOs CMS Medicare Medicare Shared Savings Program

CMS Releases Proposed New Rule for Accountable Care Organizations

On Dec. 1st, the Centers for Medicare and Medicaid Services released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). The voluminous proposal covers a...more

12/5/2014 - ACOs CMS Comment Period Healthcare Medicare Shared Savings Program Proposed Regulation

Sometimes the Government is Here to Help: OIG Proposes More Flexibility in Rules Governing Local Transportation, Beneficiary...

The U.S. Department of Health & Human Services, Office of Inspector General ("OIG") just released a proposed rule (“Proposed Rule”) that provides long awaited guidance on patient transportation services, relaxes the...more

10/6/2014 - Affordable Care Act Anti-Kickback Statute Cost-Sharing Gainsharing HHS Hospitals Medicaid Medicare Medicare Part D OIG Physician Payments Physicians Proposed Regulation Retailers Transportation Expenses

The Dark Side of Health Care Reform: The First “60-Day Rule” False Claims Act Case

The U.S. Department of Justice and New York State Attorney General’s Office recently intervened in a federal False Claims Act case in federal District Court based on allegations that a provider failed to report and refund an...more

7/11/2014 - Affordable Care Act DOJ False Claims Act Healthcare Reform Hospitals Overpayment Reporting Requirements

Legislature Amends Washington Anti-Rebate Statute

In a thoughtful amendment to Washington’s Anti-Rebate Statute, the Legislature has aligned the parameters of chapter 19.68 RCW with those of the federal Anti-Kickback Statute, granting greater protection for EHR donation...more

12/11/2013 - Anti-Corruption Anti-Kickback Statute Anti-Rebate Statutes Charitable Donations EHR New Legislation

Influential Appeals Court Rejects Attempt by Former In-House Counsel to Use Privileged Information Against Company in...

The pool of potential qui tam relators may have just shrunk a little, based on a recent decision by the 2nd Circuit Court of Appeals that has put the ability of in-house lawyers to become qui tam relators into serious...more

11/20/2013 - Attorney-Client Privilege Confidential Information Corporate Counsel Legal Ethics Qui Tam Whistleblowers

Sebelius: "Qualified Health Plans Are Not Federal Health Care Programs"

In a letter to Rep. Jim McDermott dated Oct. 30, 2013, Department of Health and Human Services Secretary Kathleen Sebelius clarified that qualified health plans (“QHPs”) available on the health insurance exchanges under the...more

11/6/2013 - Affordable Care Act Anti-Kickback Statute Health Insurance Exchanges Healthcare HHS Kathleen Sebelius Qualified Health Plans

Washington Attorney General's Office Opinion Undermines Electronic Health Records Donation Programs

In 1949, the Washington Legislature enacted what has become known as the “anti-rebate statute,” codified as RCW Chapter 19.68. Rep. Eileen Cody recently asked the state Attorney General (AG)’s Office whether this statute...more

12/13/2012 - Anti-Rebate Statutes Charitable Donations Clinical Laboratories Electronic Health Record Incentives Electronic Medical Records

False Claims Act Case Limits Attorney-Client Privilege for In-House Counsel

Health care organizations should take careful note of a recent decision from a Florida federal district court that sharply limited the defendant hospital’s ability to shield what it considered to be attorney-client...more

11/30/2012 - Attorney-Client Privilege False Claims Act

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