News & Analysis as of

Ambulance Providers Medicare

What’s in Your Local Transportation Policy?

by Nossaman LLP on

Those in the business of providing healthcare services to Medicare and Medicaid beneficiaries are all too familiar with the federal Anti-kickback Statute (AKS). Among other dreadful sanctions, it imposes criminal penalties on...more

HHS OIG Revises Various Safe Harbors Related to Beneficiary Inducements

by McGuireWoods LLP on

On Dec. 7, 2016, the U.S. Department of Health and Human Services’ (HHS’) Office of Inspector General (OIG) published a final rule revising federal Anti-Kickback Statute (AKS) safe harbors and the beneficiary inducement...more

OIG Creates New AKS Safe Harbors, Codifies Others

by Dorsey & Whitney LLP on

On January 6, 2017, two new safe harbors to the federal anti-kickback statute (the “AKS”) will become effective pursuant to a final rule published by the United States Department of Health and Human Services Office of the...more

New Anti-Kickback Safe Harbors

by Roetzel & Andress on

On December 7, 2016, the Department of Health and Human Services (HHS), Office of Inspector General (OIG), issued a final rule creating additional “safe harbors” for the Federal Anti-Kickback Statute (42 USC § 1320a-7b(b) et...more

OIG Recognizes New Local Transportation Safe Harbor and Exceptions to CMP in Updated Fraud and Abuse Regulations

by Robinson & Cole LLP on

On December 7, 2016, the Department of Health and Human Services Office of Inspector General (OIG) issued a long-awaited final rule (Final Rule) that expands the safe harbor regulations under the Anti-Kickback Statute (AKS)...more

HHS OIG Adopts NewAnti-Kickback Safe Harbor and Civil Monetary Penalty Exceptions

by Proskauer Rose LLP on

On December 7, 2016, the Department of Health and Human Services (HHS), Office of Inspector General (OIG), issued a final rule that will have a widespread impact on health care service providers, medical transport providers,...more

OIG Revises Safe Harbors under the Anti-Kickback Statute and Civil Monetary Penalty Rules Regarding Beneficiary Inducements

by McDermott Will & Emery on

On December 7, 2016, the Office of Inspector General of the US Department of Health and Human Services published a final rule containing revisions to both the federal Anti-Kickback Statute safe harbors and the beneficiary...more

OIG Finalizes New and Expanded Anti-Kickback Safe Harbors, Issues Guidance Regarding Nominal Gifts

by Buchalter on

In an uncertain health care environment following the presidential election, the Department of Health & Human Services Office of Inspector General (“OIG”) finalized a new rule expanding existing safe harbors to the federal...more

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

by Baker Ober Health Law on

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

by Faegre Baker Daniels on

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

by Reed Smith on

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

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

by Reed Smith on

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

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

by Reed Smith on

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 Identifies Potentially Improper Medicare Ambulance Payments

by Reed Smith on

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

by Reed Smith on

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

by BakerHostetler on

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

by Foley & Lardner LLP on

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

by King & Spalding on

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

Medicare Enrollment Rules - Expanded Enforcement Finalized in Regulations

by Baker Ober Health Law on

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

OIG Announces Proposed AKS and CMP Regulations

by Benesch on

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

by BakerHostetler on

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

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

by King & Spalding on

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...

by King & Spalding on

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

by Benesch on

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

by King & Spalding on

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

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