The Centers for Medicare & Medicaid Services (CMS) recently issued a final rule (Final Rule) that implements the Comprehensive Care for Joint Replacement model (CJR Model), a new bundled payment program covering certain...more
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
In the last few months, the United States Department of Justice (DOJ) and the Office of Inspector General (OIG) have obtained over half a billion dollars in settlements and multiple criminal convictions arising from...more
On October 29, 2015, the Centers for Medicare & Medicaid Services and the Office of Inspector General of the Department of Health & Human Services (jointly, the “Agencies”) issued a final rule (Final Rule) regarding waivers...more
The Office of the Inspector General (OIG) recently issued a favorable advisory opinion (Advisory Opinion) to an integrated health care system (System) regarding a proposed arrangement whereby the System would provide a free...more
On October 16, 2015, the Centers for Medicare & Medicaid Services (CMS) published a final rule (Final Rule) that streamlines Stage 2 and finalizes Stage 3 of the Medicare and Medicaid electronichealth record (EHR) Incentive...more
11/4/2015
/ CEHRT ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
EHR ,
Electronic Health Record Incentives ,
Final Rules ,
Health Care Providers ,
Healthcare ,
Meaningful Use ,
Medicaid ,
Medicare ,
Reporting Requirements
The Health Resources and Services Administration (HRSA) recently issued proposed omnibus guidance (Omnibus Guidance) interpreting various provisions of the 340B Drug Pricing Program (340B Program). The 340B Program allows...more
10/8/2015
/ 60-Day Rule ,
Centers for Medicare & Medicaid Services (CMS) ,
Covered Entities ,
Department of Justice (DOJ) ,
Drug Pricing ,
False Claims Act (FCA) ,
Fee-for-Service ,
GPOs ,
Healthcare ,
HIV ,
HRSA ,
Managed Care Contracts ,
Medicaid ,
Medicare ,
Overpayment Recovery Time Limits ,
Patients ,
Pharmaceutical Industry ,
Pharmacies ,
Prescription Drugs ,
Section 340B ,
Whistleblowers
The U.S. Department of Justice (DOJ) recently announced that KMART Corp. (Kmart) has paid $1.4 million to settle a qui tam lawsuit brought by a former Kmart pharmacist under the False Claims Act (FCA). The lawsuit alleged...more
9/9/2015
/ Anti-Kickback Statute ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Generic Drugs ,
Healthcare ,
HEAT ,
Kickbacks ,
Kmart ,
Medicare ,
Pharmacies ,
Prescription Drugs
On August 21, 2015, the United States Court of Appeals for the District of Columbia Circuit (DC Circuit) reinstated Department of Labor (DOL) regulations that require home care agencies and other third-party employers of...more
On August 3, 2015, the United States District Court in the Southern District of New York issued a long-awaited opinion and order rejecting a motion to dismiss filed by the defendants in U.S. ex rel. Kane v. Continuum Health...more
8/21/2015
/ 60-Day Rule ,
Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Medicare Part A ,
Medicare Part B ,
Overpayment ,
Overpayment Recovery Time Limits ,
Whistleblowers
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
8/18/2015
/ Advance Directives ,
Affordable Care Act ,
Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Employees ,
Fair Market Value ,
FQHC ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Non-Profit Hospitals ,
OIG ,
Physician Fee Schedule ,
Physicians ,
Rural Health Care Providers ,
Stark Law ,
Timeshare
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
8/13/2015
/ Audits ,
Certificate of Need ,
DSS ,
FQHC ,
Health Care Providers ,
Healthcare ,
HIV ,
Home Healthcare Workers ,
Hospitals ,
Medicaid ,
Medicaid Reimbursements ,
Medical Reimbursement ,
Municipalities ,
Nurses ,
Nursing Homes ,
Pay-for-Performance ,
Personal Property ,
Prescription Drugs ,
Property Tax ,
Public Health ,
Reporting Requirements ,
Screening Procedures ,
Tax Rates
President Obama recently signed into law Public Law No. 114-10, the “Medicare Access and CHIP Reauthorization Act of 2015” (P.L. 114-10), which overhauls Medicare physician reimbursements by eliminating the use of the...more
On May 26, 2015, Connecticut Governor Dannel P. Malloy signed into law Public Act 15-11 (PA 15-11), “An Act Concerning Persons Who Decontaminate Reusable Medical Instruments or Devices.” This new legislation requires central...more
On May 11, 2015, Connecticut Governor Dannel P. Malloy signed into law Public Act 15-4, “An Act Concerning Reporting of Payments by Manufacturers to Independently-Practicing Advanced Practice Registered Nurses” (P.A. 15-4)....more
The Centers for Medicare and Medicaid Services (CMS) recently published a proposed rule (Proposed Rule) implementing Stage 3 of the Medicare and Medicaid electronic health record (EHR) Incentive Programs (Meaningful Use...more
On March 10, 2015, the Internal Revenue Service (IRS) released Revenue Procedure 2015-21 (Revenue Procedure), which will be officially published on March 30, 2015, in Internal Revenue Bulletin 2015-13. The Revenue Procedure...more
The New York State Legislature passed a bill on June 19, 2013, intended to update New York’s labor law, including the Wage Theft Protection Act (WTPA). The bill (A 8106-C, S5885-B), signed into law by Governor Andrew Cuomo on...more
The Centers for Medicare and Medicaid Services (CMS) announced on February 13, 2015, that it will delay publishing final regulations concerning the “60-Day Rule.” The final rule will be published on or before February 17,...more
The Ninth Circuit Court of Appeals and a Massachusetts Superior Court each recently released decisions dealing with alleged violations of antitrust prohibitions that implicate a number of important issues surrounding health...more
On January 23, 2015, the United States Department of Labor (DOL) filed a notice of appeal with the United States Court of Appeals for the District of Columbia (District Court) challenging two rulings in the case of Home Care...more
2/23/2015
/ Appeals ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Fair Labor Standards Act (FLSA) ,
Fee-for-Service ,
Final Rules ,
Healthcare ,
Home Health Agencies ,
Home Health Care ,
Home Healthcare Workers ,
Meaningful Use ,
Medicare ,
Quality of Care Standards ,
Wage and Hour
In This Issue:
- Connecticut Supreme Court Rules State Does Not Recognize Mature Minor Doctrine
- OIG Issues Advisory Opinion Permitting Copayment Assistance
- CMS Announces Recovery Audit Program...more
On December 31, 2014, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury Department) published final regulations (Final Regulations) that provide guidance to hospitals regarding compliance with...more
In a ruling on December 22, 2014, in the case of Home Care Association of America et al. v. Weil, the US District Court for the District of Columbia vacated a significant new regulation in the Department of Labor’s (DOL)...more
Earlier this year, Connecticut enacted P.A. 14 - 168, which requires hospitals, hospital systems, and physician group practices composed of 30 or more physicians to report to the attorney general and the Department of Public...more