For the year ending September 30, 2023, federal False Claims Act settlements and judgments exceeded $2.5 billion, much of which came from the health care industry. The largest, at over $487 million, stems from a finding by a...more
HELPFUL HINTS -
Justice Department Reports More Than $8B In Alleged Fraud Related to COVID-19 Relief Programs -
The Washington Post reports, “Since the U.S. government first marshaled its historic economic response...more
3/17/2022
/ Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Infectious Diseases ,
Medicare ,
Surprise Medical Bills ,
Telehealth
HELPFUL HINTS -
The Federal No Surprises Act The Federal No Surprises Act (the “Act”) became fully effective on January 1, 2022. The Act protects enrollees in group and individual market plans (including ERISA plans) and...more
1/25/2022
/ Advisory Opinions ,
Anti-Kickback Statute ,
Biden v Missouri ,
Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Employer Mandates ,
Healthcare ,
Healthcare Fraud ,
Healthcare Reform ,
Healthcare Workers ,
Infectious Diseases ,
Mental Health ,
National Federation of Independent Business v Department of Labor and OSHA ,
New Legislation ,
OIG ,
OSHA ,
Surprise Medical Bills ,
Vaccinations
Helpful hints -
OIG Updates Health Care Fraud Self-Disclosure Protocol (“SDP”) -
On November 8, 2021, the OIG issued an updated SDP to providers, which included clarifications of existing guidance and increased the minimum...more
11/16/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Disproportionate Share Adjustments ,
Employer Mandates ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
OIG ,
Outpatient Prospective Payment System (OPPS) ,
Physician Fee Schedule ,
Self-Disclosure Requirements ,
Vaccinations
Since I began writing this year-end review in 2013, there have been some common themes – a shift to pay for quality and away from fee-for service, much of which has been brought about by the Affordable Care Act (ACA): efforts...more
12/12/2016
/ 60-Day Rule ,
Affordable Care Act ,
Alternative Payment Models (APM) ,
Centers for Medicare & Medicaid Services (CMS) ,
Data Breach ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
False Claims Act (FCA) ,
Health Care Providers ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Healthcare Fraud ,
HIPAA Breach ,
Hospitals ,
Implied Certification ,
Long Term Care Facilities ,
Medicaid ,
Medicare ,
Medicare Access and CHIP Reauthorization (MACRA) ,
MIPS ,
OIG ,
Overpayment Recovery Time Limits ,
PHI ,
Physicians ,
Popular ,
Premiums ,
Provider Payments ,
Quality Payment Program (QPP) ,
Trump Administration ,
Universal Health Services Inc v United States ex rel Escobar ,
Value-Based Payments
Since the enactment of the net investment income tax ("NIIT") in 2012, physicians and other taxpayers owning multiple business interests have had to make educated choices based upon accounting projections and SWAGS when...more
A femtosecond (FS) laser is exciting new technology, but it requires consideration of some important governance and compliance issues. Best practices require the surgeon and the facility (ASC or Hospital) to identify covered...more
This is Part II of a two-part series on the new Medicaid structure in Alabama. Part I of the series, which was published last month, discussed organizational and operational requirements of RCOs. This Part II will discuss the...more
On May 17, 2013, Governor Bentley signed into law Act 2013-261, Ala. Code §§ 22-6-150 et seq., which changes the Alabama Medicaid system from a fee-for-service to a managed care program (the "Act"). This historic legislation...more
Bob Dylan's quote from 1964 -- "The Times They Are A-Changin" -- could equally apply to the healthcare industry in 2013. This was the year that the Affordable Care Act ("ACA") came into full public view with the start of the...more
12/12/2013
/ Affordable Care Act ,
False Claims Act (FCA) ,
Fraud ,
Health Insurance Exchanges ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Healthcare Reform ,
Healthcare.gov ,
ICD Codes ,
MCOs ,
Medicaid ,
Medicare ,
OIG ,
Physician Medicare Reimbursements ,
Physician-Owned Distributors
Driven by Federal Health Care Reform and a desire to remain independent of hospitals and health care systems, physician groups are actively exploring different collaborative and alignment options, including the formation of...more