News & Analysis as of

FQHC

CMS Releases Proposed Rule for 2018 Physician Fee Schedule

by King & Spalding on

On July 13, 2017, CMS proposed a rule (Proposed Rule) updating payment policies and rates, as well as the quality provisions, for the Medicare Physician Fee Schedule (PFS). Among other provisions, the Proposed Rule reduces...more

April Showers Bring More HIPAA Settlements

April proved to be a busy month for the U.S. Department of Health and Human Services Office for Civil Rights (OCR) under its newly appointed director, Roger Severino. OCR announced three settlements of potential HIPAA...more

OCR Levies Hefty Fine Against FQHC

Showing no signs of letting up on enforcement actions, the Office for Civil Rights (OCR) late last week settled an investigation against Metro Community Provider Network MCPN, a Colorado based federally qualified health...more

Phishing Incident Leads to $400,000 HIPAA Settlement

by Saul Ewing LLP on

?On April 12, 2017, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced that Metro Community Provider Network (MCPN) agreed to pay HHS $400,000 to settle alleged HIPAA Security Rule...more

OIG Rings in the New Year With New Anti-Kickback Statute Safe Harbors

by Foley & Lardner LLP on

Just in time for the New Year, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued final regulations (Final Regulations) that revised two existing Anti-Kickback Statute safe...more

New Year, New Possibilities: OIG Final Rule Amends Beneficiary Inducement Rules

by Davis Wright Tremaine LLP on

The Office of Inspector General (“OIG”) of the Department of Health and Human Services has issued a final rule (“Final Rule”) adding new safe harbors to the federal anti-kickback statute, amending existing safe harbors, and...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

HHS OIG Expands Safe Harbors, but Doubles Down with Enhanced Civil Monetary Penalties

by Baker Donelson on

The Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published two rules on December 7, 2016, updating certain existing safe harbor regulations, adding new safe harbor rules under...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 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

OPPS Provider-Based Final Rule — A More Practical Approach From CMS

by Polsinelli on

CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”). CMS revealed the changes on November 1...more

Manatt on Health Reform: Weekly Highlights - May 2016

CMS encourages access to Medicaid for eligible inmates transitioning to their communities, while New York seeks to extend Medicaid coverage to eligible inmates in the days prior to release; Pennsylvania seeks to shift $6...more

A&B Healthcare Week in Review

by Alston & Bird on

I. REGULATIONS, NOTICES, & GUIDANCE - On February 24, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a guidance entitled, “Special Enrollment Confirmation Process” that will enhance program integrity...more

Alert: 340B Self-Audits: The Best Defense Is A Good Defense

by Pullman & Comley, LLC on

Federally qualified health centers (FQHCs) participating in the 340B Drug Pricing Program (the “340B Program”) are subject to audits by Health Resources and Services Administration (HRSA) and the drug manufacturers who...more

CMS Updates Manual Provisions for Rural Health Clinics and Federally Qualified Health Centers

by King & Spalding on

On December 31, 2015, CMS updated Chapter 9 of the Medicare Claims Processing Manual and Chapter 13 of the Medicare Benefit Policy Manual addressing payment and certification of Rural Health Clinics (RHCs) and Federally...more

Health Law Pulse - January 2016

by Robinson & Cole LLP on

CHANGES TO STARK LAW, NEW ADVANCE CARE PAYMENTS INCLUDED IN 2016 PHYSICIAN FEE SCHEDULE - The Centers for Medicare & Medicaid Services (CMS) recently published a final rule (Final Rule) regarding physician payment...more

New Stark Law Exception Allows Hospitals, FQHCs and RHCs to Assist Physicians with Engaging Non-Physician Practitioners

by Dickinson Wright on

The Centers for Medicare & Medicaid Services (CMS) recently released a new exception to the Physician Self-Referral Law (the “Stark Law”) intended to expand access to primary care and mental health services (the “NPP...more

CMS finalizes significant Stark Law rulemaking

by Dentons on

In July of this year, the US Department of Health & Human Services (HHS), Centers for Medicare & Medicaid Services (CMS) proposed significant changes to the regulations implementing the federal physician self referral law...more

Alert: Proposed 340B Drug Pricing Program Omnibus Guidance - Defines "Eligible Patient"

by Pullman & Comley, LLC on

On August 28, 2015, the Health Resources and Services Administration (“HRSA”) published the proposed 340B Drug Pricing Program Omnibus Guidance (“Omnibus Guidance”) which is intended to clarify for covered entities, such as...more

Baker Donelson Comments on CMS's Proposed Changes to the Stark Regulations - September 2015

by Baker Donelson on

The law firm of Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C., sincerely appreciates the opportunity to comment upon the proposed clarifications and changes to the Stark regulations issued by the Centers and Medicare...more

340B Guidance: Eight Key Points Covered Entities Should Consider

by BakerHostetler on

On August 27, 2015, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), released the 340B Drug Pricing Program Omnibus Guidance (Guidance). Referred to...more

Proposed 2016 Medicare Physician Fee Schedule Includes Changes to Stark Regulations

by Saul Ewing LLP on

The Centers for Medicare & Medicaid Services ("CMS") recently released the proposed 2016 Medicare Physician Fee Schedule (the "Proposed Rule"), which includes a number of proposed revisions to the regulations under the...more

Health Law Pulse - August 2015

by Robinson & Cole LLP on

The Office of the Inspector General (OIG) recently issued a favorable advisory opinion (Advisory Opinion) to a nonprofit health system (System) and a nonprofit psychiatric hospital (Center) regarding a proposal whereby the...more

Connecticut Enacts Health Care Legislation in June Special Session

by Robinson & Cole LLP on

On June 29 and 30, 2015, the Connecticut General Assembly conducted a special legislative session following the close of the 2015 regular session. Among other things, the General Assembly passed a bill to implement the state...more

The Implications of CMS' Proposed Stark Law Regulations

by Reed Smith on

On July 8, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released proposed regulations “to reduce burden and to facilitate compliance” under the physician self-referral law known as the Stark Law. See 80 Fed....more

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