William Mathias

William Mathias

Ober|Kaler

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Medicare Proposes Prior Authorization Process for Certain DMEPOS Items

On May 28, 2014, CMS issued a proposed rule to establish a permanent prior authorization process for certain durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) items that are “frequently subject to...more

6/9/2014 - CMS DMEPOS Enforcement Healthcare Medicare Prior Authorization Proposed Regulation

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

OIG Supplemental Special Advisory Bulletin Raises New Concerns About Independent Charity Patient Assistance Programs

In an effort to address new concerns about the independence of charity patient assistance programs (PAPs), the Office of Inspector General (OIG) released its Supplemental Special Advisory Bulletin: Independent Charity Patient...more

5/30/2014 - Anti-Kickback Statute Healthcare Medicare Medicare Part D OIG Patient Assistance Programs Pharmaceutical

Chance to Comment on Future of DMEPOS Payments

CMS recently took the unusual step of issuing an Advance Notice of Proposed Rulemaking (ANPR) regarding changes to Medicare payment methodologies for durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS)...more

3/26/2014 - Affordable Care Act CMS Competitive Bidding Durable Medical Equipment Healthcare Medical Devices Medicare

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

OIG Advisory Opinions Provide Some Helpful Guidance

In spite of a slow start, the OIG has issued a number of interesting advisory opinions to date in 2013. Here are a few of the highlights. The OIG reiterated its long-standing concern about arrangements which “carve out”...more

7/19/2013 - Advisory Opinions Health Insurance Healthcare Hospitals Medicare Medigap OIG

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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