On October 9, 2019, the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) took the next step in their Regulatory Sprint to Coordinated...more
There are many health care financial arrangements where one entity has a financial obligation to another, with whom it either does business directly, or to which it makes referrals, and that obligation is either past due or...more
Lions and Tigers and Bears, Oh My! The Unexpected Laws that May Affect Your Telehealth Business - An increasing number of health care providers are exploring telemedicine, either as an adjunct to their primary physical...more
In a development that is limited in scope but still welcomed by hospitals, the proposed 2016 Physician Fee Schedule proposes a number of new exceptions to the physician self-referral or Stark law and other refinements that...more
This operations guide provides a brief look at health law issues hospitals deal with on a daily basis. While a detailed coverage of the elements, drafting, implementation and continued governance of a hospital compliance...more
On July 2, 2015, the United States Court of Appeals for the Fourth Circuit affirmed a $237 million judgment against Tuomey Healthcare System, Inc., in a federal False Claims Act (FCA) case arising out of violations of the...more
On the way to authorizing direct access to physical therapy, the California legislature may have broadly loosened the restrictions on numerous business arrangements imposed by California’s corporate practice ban. AB 1000,...more
In this Issue: - AB 1000 and Corporate Practice in California: More than Meets the Eye—or Less? - Loose Lips Sink Ships and Careless E-mails Torpedo a Transaction - New Faces - Points from the...more
The CMS Self-referral Disclosure Protocol – Background - Under delegated authority, the Centers for Medicare and Medicaid Services (CMS) released its Self-Referral Disclosure Protocol (SRDP) on September 23, 2010, with...more
CMS has released its responses to eight frequently asked questions [PDF] regarding its Self-Referral Disclosure Protocol (SRDP). The questions fall into three categories, listed below, and respond to issues that are often...more
Representative Jim McDermott (D-Wash.), Ranking Member of the Ways and Means Subcommittee on Health, and the lead author of the provision in the Affordable Care Act establishing the CMS Self-Referral Disclosure Protocol...more
The U.S. Government Accountability Office (GAO) recently published the results of a study examining trends in the number of self-referred anatomic pathology services and the impact on Medicare spending. Anatomic pathology...more
On April 10, 2013, President Obama released his budget proposal for fiscal year (FY) 2014 (the Budget). The President reiterated his long-standing goal of reducing the deficit by $4.3 trillion over 10 years and his...more
On January 10, 2013, the U.S. Court of Appeals for the Eleventh Circuit ruled in Fresenius Medical Care Holdings, Inc. v. Tucker, that an arrangement can violate Section 456.053 of the Florida Statutes, also known as...more
The U.S. Department of Justice (DOJ) recently issued a press release related to a settlement agreement between the U.S. Attorney's Office for the District of New Jersey, the state of New Jersey and the Cooper Health System...more
On January 10, 2013, the Eleventh Circuit issued an opinion holding that Florida’s patient self-referral law is not preempted by the federal Stark law. The court also found that Florida’s law does not violate the Commerce or...more