Ambulance Providers

News & Analysis as of

Health Alert (Australia) October 24, 2016

In This Issue: - Judgments; Legislation; and Reports. - Excerpts from Judgments: Victoria 19 October 2016 - Damir Redzepovic v Western Health [2016] VSCA 251 The applicant sought leave to appeal from...more

Ambulance and Home Health Moratorium Continued and Expanded

The Centers for Medicare and Medicaid Services (CMS) recently announced an extension of its temporary moratorium on enrolling new nonemergency ambulance suppliers in New Jersey, Pennsylvania and Texas and new home health...more

CMS Lifts Temporary Moratorium on Emergency Ground Ambulance Suppliers but Extends and Expands Other Moratoria

On July 29, 2016, CMS announced that it is lifting a temporary moratorium on Medicare Part B, Medicaid, and Children's Health Insurance Program (CHIP) emergency ambulance suppliers, but extending and expanding similar...more

What’s In a Name? Or, the Importance of Emphasis

I.A. Khair of New Jersey ran an ambulance company called K&S Invalid Coach. Presumably, “Invalid” was pronounced IN-va-lid, with the emphasis on the first syllable. Maybe it should have been pronounced in-VAL-id, with the...more

CMS Announces Changes to HHA/Ambulance Supplier Enrollment Moratoria, New Exception Process Demo

CMS has announced a number of changes to its temporary Medicare enrollment moratoria for certain provider types in select geographic areas as a mechanism to address fraud, waste, and abuse. First, CMS is extending for six...more

Under the Dome: Inside the Maine State House

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Governor Paul LePage Signs Executive Order to Pay for Bills Passed in Second Regular Session of...more

CMS Announces Extension of Moratoria on Enrollment of HHAs, Ambulance Suppliers in Designated Areas

CMS published a notice February 2, 2016 announcing an additional 6-month extension of its current temporary Medicare enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs), subunits, and...more

District Court Dismisses Government’s False Claims Act Complaint for Failure to Allege Actual False Claims with Particularity

On January 7, 2016 the United States District Court for the Middle District of Florida took the rare step of dismissing (with leave to amend) the government’s Complaint in Intervention in a False Claims Act Case. This case...more

CMS Expands Medicare Prior Authorization Model for Repetitive Scheduled Non-Emergent Ambulance Transport

As previously reported, CMS announced in November 2014 that it would test a Medicare prior authorization process for repetitive scheduled nonemergent ambulance transport services in New Jersey, Pennsylvania, and South...more

OIG Targets Questionable Billing Practices for Ambulance Services

The Office of the Inspector General (“OIG”) pulled no punches in a recent report on Medicare Part B billing for ambulance transports. The September release presented a case for increased scrutiny, pointing out that Medicare...more

OIG Identifies Potentially Improper Medicare Ambulance Payments

In response to rising Medicare Part B payments for ambulance transports and continuing concerns about program vulnerabilities, the OIG has once again reviewed Medicare claims for ambulance services. The OIG estimates that...more

CMS Again Extends Moratoria on Enrollment of HHAs, Ambulance Suppliers in Designated Areas

CMS has announced another 6-month extension of its current temporary enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs), subunits, and branch locations in designated metropolitan areas....more

The Deeper Dive: C-Suite to Prison Pipeline

In recent years, the U.S. Department of Justice (DOJ) has been criticized for failing to prosecute executives for fraud, particularly in the financial sector. In response, the DOJ has begun to more heavily emphasize...more

Roadmap to Prison: Lessons Learned from the Criminal Prosecution of Alpha Ambulance’s Leaders

No one running an ambulance company ever planned to go to prison for doing his or her job. But that is a real possibility if the government knocks on the door, and the owner or manager is dishonest in his or her response to...more

CMS Extends Moratoria on Enrollment of New Providers and Suppliers in Six Locales

Last week, CMS announced that it has extended temporary moratoria on the enrollment of new ambulance suppliers and home health agencies within designated metropolitan areas in Florida, Illinois, Michigan, Texas, Pennsylvania,...more

Courts Firm Up Compensability for Employees’ Break Periods

The Sixth Circuit Court of Appeals decided two cases in January 2015 notably affirming that under the Fair Labor Standards Act, 29 U.S.C. 201, et seq. an employee’s break period is only compensable if the employee spends that...more

Medicare Enrollment Rules - Expanded Enforcement Finalized in Regulations

On December 5, 2014, CMS published final regulations that expand the bases for CMS to deny enrollment or revoke billing privileges of an enrolled provider or supplier. These final regulations also change the method to...more

Enrollment: A New Enforcement Tool?

On December 3, 2014, CMS issued its Final Rule that addresses provider enrollment. These new rules create new tools to police provider enrollment. CMS now has the ability to deny enrollment of providers, suppliers and owners...more

No Sanctions for Basic Life Support Service Provider

The Office of Inspector General (OIG) recently issued Advisory Opinion 14-09 [PDF] and concluded that a town that uses tax revenues to cover out-of-pocket expenses owed for basic life support (BLS) emergency ambulance...more

OIG's 2015 Work Plan Highlights Departmental Priorities

Each year the Department of Health and Human Services, Office of the Inspector General (OIG) issues its Work Plan to identify for the provider community the key fraud and abuse issues on which it will focus on in the coming...more

The Game Plan for Health Care Enforcement: Office of Inspector General Releases 2015 Work Plan

The Office of Inspector General (“OIG”) within the federal Department of Health and Human Services (“HHS”) is charged with protecting the integrity of HHS programs by combating fraud, abuse and waste. On Halloween of 2014,...more

For Single-Enterprise Immunity, the Bottom Line May Be Having One Bottom Line

A federal court in Ohio has provided some of the clearest guidance to date on the application of the single-enterprise immunity doctrine to healthcare organizations. The single-enterprise immunity doctrine is critically...more

Analysis of HHS OIG Proposed Rule to Amend the Anti-Kickback Safe Harbors, CMP Rules on Beneficiary Inducements & Gainsharing...

On October 3, 2014, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) published a major proposed rule that would amend the safe harbors to the Anti-Kickback Statute (AKS) and the Civil...more

OIG Announces Proposed AKS and CMP Regulations

On October 3, 2014, the Office of the Inspector General (“OIG”) issued a proposed rule codifying into regulation several statutory changes to the Antikickback Statute (“AKS”) and the Civil Monetary Penalty (“CMP”) Law. Nearly...more

OIG Special Advisory Bulletin Provides Guidance on Application of Federal Anti-Kickback Statute to Pharmaceutical Manufacturer...

In recent years, copayment coupon programs have become standard promotional practices for both large and small pharmaceutical manufacturers. Copayment coupons are typically offered to commercially insured patients in order to...more

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