Samantha Flanzer

Samantha Flanzer

Ober|Kaler

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Overview of the FY 2015 IRF Final Rule

On August 6th, the Centers for Medicare and Medicaid (CMS) published an Inpatient Rehabilitation Facility (IRF) final rule [PDF] in the Federal Register outlining (1) new Medicare payment policies and rates; and (2) guidance...more

8/22/2014 - CMS Healthcare Inpatient Quality Reporting IRF Claim Processing

Discount Drug Program Passes OIG Scrutiny

On July 28th, 2014, the Department of Health and Human Services, Office of Inspector General (OIG) released favorable advisory opinion 14-05, concluding that a pharmaceutical manufacturer’s direct-to-patient discounted, cash...more

8/14/2014 - Anti-Kickback Statute Civil Monetary Penalty Drug Manufacturers HHS OIG Pharmaceutical Manufacturers Prescription Drugs

Proposed Hospice Rule Focuses on Unbundling of Services

On May 8, CMS released a proposed rule in the Federal Register providing for a payment increase of 1.3 percent for fiscal year (FY) 2015. Among other provisions, CMS’s proposed rule offers hospice providers an update on...more

6/13/2014 - Bundling Rules CMS Healthcare Hospice Medicare Medicare Part D

OIG Proposes Updates to Exclusion and CMP Authority

The Department of Health and Human Services, Office of Inspector General (OIG) recently issued a pair of proposed regulations to update its exclusion and civil monetary penalty (CMP) authority. The proposed regulations...more

6/3/2014 - Affordable Care Act Civil Monetary Penalty CMS Compliance Exclusions Healthcare Healthcare Reform HHS Medicaid Medicare OIG

Medicare Bad Debt: Courts Again Uphold HHS's Stringent "Must Bill" Policy Requirements

On March 25, 2014, the United States District Court for the District of Maine upheld the decision of the Department of Health and Human Services (HHS) to withhold from Maine Medical Center (MMC), Medicare reimbursement for...more

5/5/2014 - Healthcare HHS Medicare

Program Integrity Priorities Revealed in FY 2015 HHS Budget

On March 14, 2014, President Obama unveiled his Administration’s proposed fiscal year 2015 budget for the Department of Health and Human Services (HHS). In total, the Administration is seeking $77.1 billion to fund HHS in FY...more

3/14/2014 - Affordable Care Act CMS Federal Budget Healthcare Fraud Healthcare Reform HHS Medicare Physician Medicare Reimbursements Stark Law

OIG's 2014 Work Plan: A Roadmap to Key OIG Fraud and Abuse Priorities

The Department of Health and Human Services, Office of the Inspector General (OIG) released its Fiscal Year (FY) 2014 Work Plan on January 31, 2014. While the OIG usually releases its work plan in October of each year, in...more

2/13/2014 - CMS Compliance Fraud and Abuse Healthcare Medicaid Medicare OIG

CMS Clarifies Broad Scope of Hospices' Payment Responsibility for Part D Drugs

In a December 6, 2013 memorandum [PDF] to all Medicare hospice providers and Part D plan sponsors, CMS expressed concern that drugs covered under the Part A hospice benefit are being billed to Part D inappropriately....more

2/10/2014 - CMS Healthcare Hospice Medicare Medicare Part D Prescription Drugs

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