News & Analysis as of

OIG Recommends Improvements to Skilled Nursing Facility Billing Policies Regarding Changes in Therapy

The Department of Health and Human Services Office of Inspector General (OIG) recently issued a report that calls for CMS to accelerate its efforts to implement a new method for paying for changes in skilled nursing facility...more

Medicaid Managed Care Update: A Middle Ground for Network Adequacy Standards

This article is part of a series that takes an in-depth look at several proposals that would affect managed care organizations, health care providers and other industry stakeholders participating in, and contracting with...more

OIG Report Raises Serious Medicare Part D Fraud, Waste and Abuse Concerns

Last month, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services released a comprehensive report and data brief detailing its concerns about the ability of Medicare Part D sponsors – as...more

CMS Addresses Current Position on Supervision and Practitioner Qualifications Under ‘Incident-To’ Billing Rules

Among the proposed changes to Medicare regulatory requirements related to billing and coverage of physician services set forth in the 2016 Medicare Physician Fee Schedule Proposed Rule (the Proposed Rule), the Centers for...more

Washington Healthcare Update

This Week: Senate Reauthorizes Older Americans Act; Bill Heads to the House... White House Holds 2015 Conference on Aging and Launches Several New Administration Healthy Aging Initiatives Enveloping Alzheimer’s, Dementia,...more

Blog: CMS Announces that Data Analytics has Prevented $820M in Improper Medicare Payments

The Office of Inspector General (OIG) recently certified the “positive return on investment” from the FPS and recommended its continued operation, although the OIG determined that it was not feasible at this time to expand...more

OIG Adds New Litigation Unit Focused on Fines and Exclusions

On June 30, 2015, the Department of Health and Human Services’ Office of Inspector General (OIG) announced that it would be staffing a new specialty litigation unit whose sole focus will be on levying civil monetary penalties...more

Health Care Update - July 2015

In This Issue: - Medicare Releases Set of Payment Rules, Physician Fee Schedule on Deck - Implementation of the Affordable Care Act - Federal Regulatory Initiatives - Congressional Initiatives - Other...more

OIG Issues New Report On SNF Billing For Therapy Services

On June 5, 2015, the Department of Health and Human Services Office of Inspector General (OIG) released another study in its continuing scrutiny of skilled nursing facilities (SNFs) and therapy services: Skilled Nursing...more

Recent OIG Audits of Home Health and Hospice Surveys May Signal Increased Scrutiny on Worker Qualifications

Recent audits by the Department of Health and Human Services Office of Inspector General (“OIG”) conclude that state survey agencies in a number of states and a leading national accrediting agency serving the home health and...more

Part D Woes, According to the OIG

On June 23, 2015, the OIG issued two reports focusing on fraud, waste, and abuse in the Part D program, the first “Ensuring the Integrity of Medicare Part D” and the second “Questionable Billing Practices and Geographic...more

Increased OIG Scrutiny on Medical Directorships

On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) released a Fraud Alert entitled, "Physician Compensation Arrangements May Result in Significant Liability." The Alert is an...more

Health Care E-Note - June 2015

In This Issue: - Why, Again, Do You Think That Worker is an Independent Contractor? - I-9 and E-Verify Compliance Practices for Temporary Labor and Contractors - Excerpt From Why, Again, Do You Think That...more

OIG Advisory Opinion Approves Patient Subsidies For Clinical Study

On June 4, 2015, OIG published an advisory opinion (No. 15-07) stating that it will not impose administrative sanctions on a medical device manufacturer that planned to pay for copayments and certain other costs for Medicare...more

An Apple a Day Keeps the OIG Away: Practical Guidelines for Structuring Physician Compensation Arrangements to Avoid Kickback...

On June 9, 2015, the Office of the Inspector General of the Department of Health and Human Services (OIG) released a fraud alert warning physicians to scrutinize carefully the conditions and terms of any medical director or...more

Blog: OIG Releases Updated Mid-Year Work Plan: Open Payments, Clinical Laboratory Payments & Opioid Billing Trends Added to Agenda

The Health and Human Services Office of Inspector General (OIG) released last week an updated mid-year Work Plan for FY2015, which removes items that have been completed, postponed, or canceled and includes new items that...more

Senate Aging Committee Hearing on Hospital Observation Stay Policies

On May 20, 2015, the Senate Special Committee on Aging held a hearing entitled “Challenging the Status Quo: Solutions to the Hospital Observation Stay Crisis.” Chairman Susan Collins (R-ME) and Ranking Member Claire...more

OIG Reviews HHA Background Check Policies

In response to a Congressional request, the OIG has reviewed the extent to which home health agencies (HHAs) have employed individuals with criminal convictions and whether state requirements should have disqualified such...more

OIG Flags Overpayments Due to Incorrect Physician Place-of-Service Coding

According to a recent OIG report, "Incorrect Place-of-Service Coding Resulted in Potential Medicare Overpayments Costing Millions,” physicians did not always correctly code the place of service on Part B claims. This...more

Reasonable Suspicion of a Crime in a Long-Term Care Facility and OIG Findings

On June 17, 2011, CMS published a memorandum detailing the reporting requirements when there is a reasonable suspicion of a crime in a long-term care facility as required by section 1150B of the Social Security Act....more

Also In The News - Health Headlines - April 2015 #4

CMS Announces Round 1 2017 DMEPOS Competitive Bidding System – On April 21, 2015, CMS announced plans for a new bidding process for the supplier contracts awarded in the Round 1 Recompete of the DMEPOS Competitive Bidding...more

New Postings on the Reed Smith Health Industry Washington Watch Blog - April 2015

The Reed Smith Health Industry Washington Watch blog has been updated to report on recent health policy developments, including the following...more

Also In The News - Health Headlines - April 2015 #3

OIG Releases Joint Compliance Guidance for Hospital – In a first-of-its-kind collaboration, the HHS Office of Inspector General (OIG) has released a new guidance document, “Practical Guidance for Health Care Governing Boards...more

Health Care E-Note - April 2015

In This Issue: - New Smartphone Software Provides Groundbreaking Opportunity for Medical Research - The Many Levels of Supervision - Health Care Business Today: A Historical Perspective on Health Care...more

Look Out for Meaningful Use Audits by the Office of Inspector General

The Medicare and Medicaid Electronic Health Care Record (“EHR”) Incentive Program (commonly referred to as “Meaningful Use”) provides incentive payments to eligible physicians and hospitals for adopting, implementing,...more

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