News & Analysis as of

RAC Program Update: CMS Appoints Provider Relations Coordinator

On June 2, 2014, CMS posted a brief update on its Recovery Audit Contractor (RAC) program website announcing the creation of a “Provider Relations Coordinator” position within CMS. The announcement states that the role of...more

As Sunshine Act Reporting Deadline Looms, CMS Issues Additional Guidance

With the June 30 deadline for Phase 2 Sunshine Act reports by pharmaceutical and medical device manufacturers (“Applicable Manufacturers”) and group purchasing organizations (“GPOs’) quickly approaching, the Centers for...more

Cloudy Skies Ahead for Providers? CMS’ Release of Medicare Billing Data Combined with Physician Payment Sunshine Act Data May...

In February 2013, we reported (on our Healthcare Law Blog) that the Centers for Medicare and Medicaid Services (CMS) announced the final rule for the Physician Payments Sunshine Act. In the interest of providing more...more

The push for greater transparency in healthcare continues

Recently, CMS released the proposed fiscal year 2015 Inpatient Prospective Payment System (IPPS) rule for inpatient stays in long-term and general acute care hospitals. Included among the regular updates to Medicare payment...more

CMS Releases 2012 Physician Medicare Data: Five Takeaways

On April 9, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released the Medicare Provider Utilization and Payment Data: Physician and Other Supplier Public Use File (the “Data File”). The Data File contains...more

Department of Health and Human Services to Release Medicare System Data

Last week, the Department of Health and Human Services (HHS) announced that they will begin to publicly release Medicare system data, including payment and utilization rates, for the 880,000 physicians currently participating...more

I’ll Be Watching You: Medicare Billing Info on over 880,000 Providers Released by CMS to Improve Transparency

Every payment you take, every claim you make, someone will be watching you. No, we don’t mean Sting. We mean all the consumers and businesses that will have greater access to physician billing information now because today...more

CMS Issues New Policy on Disclosure of Physician Payment Information

On January 17, 2014, the Centers for Medicare & Medicaid Services (CMS) announced that it will release Medicare expenditure data on specific physicians under the Freedom of Information Act (FOIA). This new “transparency”...more

Transparency Update: U.S. Sunshine Collection Obligations Take Effect

Many organizations continue to face challenges with the technology and integration of some of the more complex interpretations. On August 1, the U.S. Sunshine Act and its data collection obligations took effect....more

Increased Availability of Health Care Data Means More Oversight and More Litigation

The increasing availability of health care claims and payment data may portend the future of government and private health care enforcement and litigation. ...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Reports on Physician Ownership...

Reports on Physician Ownership and Investment Interests The Sunshine Act requires applicable manufacturers, as well as applicable GPOs, to report to the Secretary, in electronic form, certain information concerning...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Report Submission and Review

Report Submission and Review Pre-Submission Review is Not Required Applicable manufacturers may voluntarily provide covered recipients the opportunity to review the data prior to submission to CMS, but doing so is not...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!: Payments or Other Transfers of...

“Payments or Other Transfers of Value” Payments or Other Transfer of Value Must Have a Discernible Economic Value.In the Final Rule, CMS interprets value as the discernible economic value on the open market in the United...more

CMS Releases Final Rule on Physician Payment Disclosures

Public disclosure of payments from pharmaceutical, medical device, biologic, and medical supply manufacturers to physicians and hospitals will begin under a final rule on the Physician Payments Sunshine Act (Sunshine Act)...more

Healthcare Alert: Better Late than Never - The Sunshine Act Final Regulations are Finally Here!

Late afternoon on Friday February 1, 2013, the Centers for Medicare and Medicaid Services ("CMS") published the final rule regarding Transparency Reports and Reporting of Physician Ownership or Investment Interests ("Final...more

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