On August 28, as part of its Fiscal Year 2025 Hospital Inpatient Prospective Payment System (IPPS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) finalized the Transforming Episode Accountability Model (TEAM)...more
8/29/2024
/ Acute Facilities ,
Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Final Rules ,
Health Care Providers ,
Hospitals ,
Inpatient Prospective Payment System (IPPS) ,
Mandatory Requirements ,
Medicare Part A ,
Medicare Part B ,
Value-Based Payments
The Centers for Medicare & Medicaid Services (CMS) recently proposed the Transforming Episode Accountability Model (TEAM) – a new, mandatory, episode-based alternative payment model in the Fiscal Year 2025 Hospital Inpatient...more
We are pleased to bring you our 12th annual Healthcare Fraud & Abuse Review. Our Review provides comprehensive coverage of the most significant civil and criminal enforcement issues facing healthcare providers. Each year, we...more
2/27/2024
/ Anti-Kickback Statute ,
CARES Act ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Kickbacks ,
Medical Devices ,
Pharmaceutical Industry ,
Physicians ,
Prescription Drugs ,
Qui Tam ,
Settlement ,
Stark Law ,
Telemedicine
On November 16, the Centers for Medicare & Medicaid Services (CMS) published its Medicare Physician Fee Schedule (PFS) final rule for calendar year 2024 (PFS Final Rule). According to the CMS press release, the PFS Final Rule...more
11/21/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Final Rules ,
Health Care Providers ,
Healthcare ,
Healthcare Facilities ,
Healthcare Reform ,
Medical Reimbursement ,
Medicare ,
Mental Health ,
New Regulations ,
Outpatient Prospective Payment System (OPPS) ,
Outpatient Services ,
Physician Fee Schedule ,
Physicians ,
Psychological Counseling ,
Telehealth
On September 25, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion 23-06, in which it declined to approve an anatomic pathology laboratory’s proposal to purchase...more
The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued Advisory Opinion 23-03, approving a proposal by the manufacturer of a colorectal cancer screening test and its wholly owned...more
The Health Resources and Services Administration (HRSA) is seeking repayment of Provider Relief Fund (PRF) payments from providers who failed to submit the required report(s) on their use of the funds. Recipients were...more
On August 19, the federal government issued a final rule addressing certain aspects of the No Surprises Act (NSA). The NSA was enacted in December 2020 to protect commercially insured patients from receiving surprise medical...more
On July 1, the Department of Health and Human Services (HHS), Department of Labor, and Department of the Treasury (Departments) jointly issued interim final rules (IFR) implementing certain aspects of the No Surprises Act...more
8/9/2021
/ Comment Period ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Federal Employees ,
Health Care Providers ,
Health Insurance ,
Healthcare Facilities ,
Interim Final Rules (IFR) ,
Notice Requirements ,
Out of Network Provider ,
Patients ,
Proposed Regulation ,
Rulemaking Process ,
State and Local Government ,
Surprise Medical Bills ,
U.S. Treasury
The Centers for Medicare & Medicaid Services (CMS) recently issued Advisory Opinion No. CMS-AO-2021-01, clarifying that physician groups that furnish designated health services (e.g., laboratory, imaging) through wholly-owned...more
After months of quiet introspection, on June 11, 2021, the U.S. Department of Health and Human Services (HHS) released long-awaited updated Post-Payment Notice of Reporting Requirements, which outlines updated reporting...more
Private equity investors’ interest in gastroenterology (GI) practices continues to remain strong, despite some headwinds that GI practices have experienced as a result of the COVID-19 pandemic and further investment in this...more
After a drawn-out drafting-and-review process, the hotly contested No Surprises Act (Act) has made its way into law after being tucked into the 5,500+ pages of the Consolidated Appropriations Act, 2021, signed into law on...more
2/8/2021
/ Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Dispute Resolution ,
Health Care Providers ,
Healthcare ,
Medical Billing Codes ,
Notice and Comment ,
Patients ,
Price Transparency ,
Proposed Rules ,
Reimbursements ,
Reporting Requirements ,
Stakeholder Engagement ,
Surprise Medical Bills ,
Telehealth
Ensuring compliance with the False Claims Act has never been more important for healthcare providers. By March 2020, we saw healthcare professionals standing at the forefront of one of the greatest health crises in a...more
2/4/2021
/ Annual Reports ,
Anti-Kickback Statute ,
CARES Act ,
Coronavirus/COVID-19 ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Fraud ,
Long Term Care Facilities ,
Medical Devices ,
Medicare ,
Medicare Advantage Organizations (MAOs) ,
Nurses ,
Nursing Homes ,
OIG ,
Opioid ,
Pharmaceutical Industry ,
Pharmacist ,
Physicians ,
Qui Tam ,
Settlement Agreements ,
Stark Law ,
Telemedicine
In a coordinated effort, on November 27, 2020, the Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) published final rules to modernize regulations implementing the federal...more
12/22/2020
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Final Rules ,
Health Care Providers ,
New Value Exception ,
OIG ,
Pharmacy Benefit Manager (PBM) ,
Physicians ,
Rebates ,
Safe Harbors ,
Stark Law ,
Technology Sector
On December 4, the U.S. Department of Health and Human Services (HHS) revised its Public Health and Social Services Emergency Fund (Relief Fund) Frequently Asked Questions (FAQs), indicating that providers must return Relief...more
12/9/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Financial Reporting ,
Health Care Providers ,
Healthcare Facilities ,
Hospitals ,
Income Taxes ,
Provider Payments ,
Provider Relief Fund ,
Public Health Emergency ,
Relief Measures ,
Tax Revenues
The Health Resources and Services Administration (HRSA) quietly released a Post-Payment Notice of Reporting Requirements (Notice) over the weekend, which provides some initial details regarding the reporting requirements...more
9/23/2020
/ Borrowers ,
CARES Act ,
Coronavirus/COVID-19 ,
Deadlines ,
Guidance Update ,
Health Care Providers ,
HRSA ,
Provider Relief Fund ,
Reimbursements ,
Relief Measures ,
Reporting Requirements ,
Time Extensions
Anyone conducting COVID-19 testing – whether using point of care or high complexity tests – should take note. On August 25, the Centers for Medicare & Medicaid Services (CMS) released an Interim Final Rule with comment period...more
9/1/2020
/ CARES Act ,
Centers for Medicare & Medicaid Services (CMS) ,
CLIA ,
Clinical Laboratories ,
Coronavirus/COVID-19 ,
Enforcement Actions ,
Health Care Providers ,
Interim Final Rules (IFR) ,
Long Term Care Facilities ,
Medicare ,
Physicians ,
Reporting Requirements ,
Urgent Care Facilities ,
Virus Testing
On Sunday, August 23, the Food & Drug Administration (FDA) issued an Emergency Use Authorization (EUA) for investigational COVID-19 convalescent plasma (CCP) for the treatment of COVID-19 in hospitalized patients. This EUA...more
The U.S. Department of Health and Human Services (HHS) recently issued new guidance regarding reporting and auditing requirements that may impact providers and suppliers who retain payments received from the Public Health and...more
8/10/2020
/ Audit Policies ,
Children's Health Insurance Program (CHIP) ,
Department of Health and Human Services (HHS) ,
Health Care Providers ,
Hospitals ,
Medicaid ,
New Guidance ,
Provider Relief Fund ,
Secretary of HHS ,
Skilled Nursing Facility ,
Suppliers
On Tuesday, June 9, the U.S. Department of Health and Human Services (HHS) announced in a press release that it expects to distribute approximately $15 billion from the Public Health and Social Services Emergency Fund (Relief...more
On Friday, May 22, the U.S. Department of Health and Human Services (HHS) issued a press release announcing that it has begun distributing nearly $4.9 billion to skilled nursing facilities (SNFs) to “support nursing homes...more
Following the announcement of additional allocations from the $100 billion Public Health and Social Services Emergency Fund (PHSSEF) under the CARES Act, on April 24, the U.S. Department of Health and Human Services (HHS)...more
On April 21, the U.S. Senate approved an additional $100 billion in funding for the Public Health and Social Services Emergency Fund established under the CARES Act, including $75 billion for eligible healthcare providers and...more
On Wednesday, April 22, the U.S. Department of Health and Human Services (HHS) issued a press release announcing additional allocations from the $100 billion Public Health and Social Services Emergency Fund (PHSSEF) for...more