Ambulance Providers

News & Analysis as of

Health Law Alert: OIG Releases Proposed Revisions to Anti-Kickback Safe Harbors and Civil Monetary Penalty Rules

The Department of Health and Human Services Office of Inspector General (OIG) recently released a proposed rule that revises safe harbors under the Anti-Kickback Statute (AKS) and Civil Monetary Penalty (CMP) rules regarding...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

OIG Proposes New Safe Harbors to the Anti-Kickback Statute and New Exceptions to the Two Civil Monetary Penalty Provisions

On October 3, 2014, the Department of Health and Human Services’ Office of Inspector General (“OIG”) published a proposed rule (“Proposed Rule”) to add new safe harbors to the federal health care program anti-kickback statute...more

Proposed Updates to the Civil Monetary Penalties Law for Health Care Providers

On October 3, 2014, the Office of Inspector General of the Department of Health and Human Services (“OIG”) published a proposed rule and request for comments (“Proposed Rule”) that would amend certain rules under the Civil...more

OIG Proposed Anti-Kickback Safe Harbors and CMP Regulations: The End of Frustration or Just the Beginning?

On October 3, 2014, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published an unexpected, yet long-awaited, set of proposed rules that would add new anti-kickback law safe harbors,...more

Highlights of OIG's Proposal to Amend Safe Harbors to the Antikickback Statute and CMP Rules, and to Add New Safe Harbors

On October 3, 2014, the Department of Health and Human Services Office of Inspector General (OIG) issued a proposed rule to establish new safe harbors under the antikickback statute and the civil monetary penalty (CMP) rules,...more

OIG Proposes Favorable Changes To The Anti-Kickback And CMP Regulations

On October 3, 2014, the Office of Inspector General (OIG) published a favorable proposed rule that would make changes to the anti-kickback and civil monetary penalties (CMP) regulations. This proposed rule clarifies...more

A Possible Green Light for Patient Transportation Services: OIG Proposes Revised Safe Harbors to the Anti-Kickback Statute for...

On October 3, 2014, the Office of Inspector General of the Department of Health and Human Services (“OIG”) published a proposed rule and request for comments (“Proposed Rule”), which would amend the Anti-Kickback Statute...more

HHS Office of Inspector General Proposes Expansions of Anti-Kickback Safe Harbors and Civil Monetary Penalties Law Exceptions

On October 3, 2014, the Office of the Inspector General (the “OIG”) of the U.S. Department of Health and Human Services (“HHS”) issued a proposed rule that would amend regulations implementing the federal anti-kickback...more

Proposed Rule Issued by OIG Realigns Its Enforcement Views with Health Care Reform Goals

Fridays never seem to be slow in the health care regulatory world. On Friday, October 3rd, the HHS Office of the Inspector General (OIG) issued a highly anticipated proposed rule (the Proposed Rule) that provides amendments...more

OIG Releases Proposed Rule Adding New Safe Harbors to the Anti-Kickback Statute

Last week, the HHS OIG released a proposed rule published in the October 3 Federal Register that would add new safe harbors to the Anti-Kickback Statute and expand the list of conduct exempt from civil monetary penalties...more

CMS Announces Temporary Enrollment Moratoria on Home Health Agencies in Florida, Texas, and Michigan, As Well As Ambulance...

On January 30, 2014, CMS announced a temporary moratorium on Medicare enrollment of home health agencies operating in Fort Lauderdale, Dallas, Houston, and Detroit. It also announced a temporary moratorium on Medicare...more

CMS Directs MACs to Reject Part B Ambulance Claims for SNF to SNF Transfers

On November 6, 2013, CMS issued Transmittal No. 1311 which instructed Medicare Administrative Contractors (“MACs”) to reject claims for SNF to SNF ambulance transfers that are billed separately under Part B. According to CMS,...more

OIG Report Details Disproportionate Increase in Ambulance Usage

On September 24, 2013, the OIG issued a Memorandum Report titled “Utilization of Medicare Ambulance Transports, 2002-2011” analyzing the continued increases in ambulance usage among Medicare beneficiaries. The OIG found that...more

CMS Imposes Six-Month Moratoria on New Enrollments of Home Health Agencies and Ambulance Suppliers in Three Fraud “Hot Spots”

Last week, CMS announced temporary moratoria on the enrollment of new home health providers and ambulance suppliers in Medicare, Medicaid, and the Children’s Health Insurance Program (CHIP) in three fraud “hot spots.”...more

Illinois Supreme Court Extends Harris Tort Immunity to Privately Owned Ambulances

Late last week, the Illinois Supreme Court handed down its opinion in Wilkins v. Williams, holding that the state Emergency Medical Services Act makes the private owner and driver of an ambulance immune from tort liability...more

Argument Report: When You're Hit By an Ambulance on a Non-Emergency Trip

Last week, the Illinois Supreme Court heard oral argument in Wilkins v. Williams. Wilkins is a sequel of sorts to Harris v. Thompson, in which the Court considered the statutory immunity of a publicly owned ambulance involved...more

American Taxpayer Relief Act of 2012: Physician Cuts Averted, Hospitals to Carry Portion of Price Tag

Avoiding sending American taxpayers over the so-called “fiscal cliff,” Congress enacted the American Taxpayer Relief Act of 2012 (the “Act”) [PDF] that was signed into law on January 2, 2013. Of biggest note, the Act included...more

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