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The New Capitation – What Goes Around, Comes Around!

On April 23, 2018, CMS issued a request for information on direct provider contracting models. In that request, (attached hereto as a PDF), CMS stated as follows...more

Employment Performance Review Excluded from Peer Review Confidentiality

The Pennsylvania Supreme Court ruled, on March 27, 2018, in Regenelli v. Boggs, Monogahela Valley Hospital and UPMC/ERMI that physician performance reviews of an ER physician, who was provided by ERMI to Mon Valley Hospital,...more

West Virginia Doctor Secures Temporary Restraining Order Against Medicare Exclusion

In Robie v. Price, Dr. Robie successfully obtained a temporary restraining order prohibiting CMS from terminating his Medicare billing privileges prior to the exhaustion of his administrative remedies by the U.S. District...more

Texas Telemedicine Law Finally Allows Complete Remote Treatment

The Texas Medical Board and Teladoc have been battling for seven years, and through several rounds of litigation over whether a patient relationship can be established for purposes of providing telemedicine services without...more

Independent Medical Staff Denied Title VII Protection

It has not been unusual for employed physicians to seek the protection provided to independent medical staff members through the due process procedures provided by medical staff by-laws. The case of Levitin and Chicago...more

Basic Contract Issues for New Physician Contracts

When physicians have finally completed the medical education journey, many are confronted with a “physician employment contract,” usually from a hospital or medical practice, which could define the essential terms of their...more

CMS Posts Open Payment Data – $7.52 Billion in 2015

CMS published the 2015 Open Payment Data on June 30, 2015. CMS has presented tables in its press release showing the highest paid specialties and highest paying companies. ...more

10 Significant Physician Contracting Mistakes

1. Failure to Begin with the End in Mind. The most important provisions of your employment contract will be the provisions governing your termination rights, for two reasons. First, if the relationship goes well, chances are...more

Physician Practices Face Anti-Trust Risks, Too

On December 18, 2015, the Federal Trade Commission (FTC) announced a settlement with Keystone Orthopaedic Associates Specialists and Orthopaedic Associates of Reading, LTD, which were two of six orthopedic practices in Berks...more

CMS Stark Proposals Allow “Holdover” Arrangements and Signature Window

In July 2015, CMS released proposals to provide several new Stark Law exceptions and to clarify issues regarding existing exceptions. The full text of these proposal and CMS comments and explanations is available below....more

Telehealth News

Iowa Supreme Court Rejects Ban on Telemedicine Abortions - An Iowa Board of Medicine rule requires the presence of a physician when abortion inducing drugs are provided....more

TelaDoc Wins Injunction Against Texas Medical Board re: Telehealth Restrictions

The Federal District Court of the Western District of Texas has ruled against the Texas Medical Board and granted TelaDoc’s Motion for a Preliminary Injunction prohibiting the Texas Medical Board from enforcing new rules...more

OIG Issues Fraud Alert to Warn Hospitals and Physicians

On June 9, 2015, the OIG issued a Fraud Alert entitled “Fraud Alert: Physician Compensation Arrangements May Result in Significant Liability”. This is just a one page letter warning hospitals and physicians by stating the...more

Peer Review Privilege: Facts vs. Conclusions

All states have some degree of confidentiality protection for peer review activities and the information generated by those activities, and there is additional federal protection for information gathered and created by...more

Congress Repeals Medicare Sustainable Growth Rate (SGR)

MGMA has published the following alert: Congress repeals SGR! In a significant victory for physician group practices and MGMA, late last night the Senate voted (92-8) to approve the Medicare Access and CHIP...more

News from MGMA re SGR Repeal

Historic SGR repeal passes in House - Today, the House of Representatives passed the Medicare Access and CHIP Reauthorization Act, H.R. 2, by a vote of 392–37. This legislation permanently repeals the SGR and returns...more

No SGR Action by Senate

Senate leaves for recess with no action on SGR repeal - Despite a successful vote in the House yesterday, the Senate failed to bring to a vote legislation to repeal the flawed Medicare Sustainable Growth Rate (SGR)...more

Concierge Practice Network Subject to Malpractice Liability

In Beber v. Metzger and MDVIP, along with other physician defendants, a Florida jury awarded $8.5 million in a malpractice claim, and found MDVIP, a national concierge physician network with over 800 physicians, partially...more

Pennsylvania Superior Court Rejects Peer Review Confidential for “Business Records”

In Kates v. Doylestown Hospital, the Pennsylvania Superior Court, in a non-precedential decision, held back the Pennsylvania Peer Review Protection Act does not provide confidentiality protection for certain records....more

Global Surgery and 2015 Medicare Physician Fee Schedule

On July 21, 2014, I posted the proposed Medicare Physician Fee Schedule, and described the intent by CMS to eliminate global surgery. On November 13, 2014, CMS issued the final 2015 Medicare Physician Fee Schedule, and...more

Pennsylvania Workers Compensation Prescription Drug Reimbursement Restrictions

On October 27, 2014, the Governor signed Pennsylvania General Assembly enacted House Bill 1846, which limits both the authority and the reimbursement of physicians and providers other than pharmacies for prescription drugs. ...more

Face-to-Face Medicare Reimbursement Requirements for Home Health Certification

CMS has announced its concern regarding the level of compliance for documenting the face-to-face elements necessary for home health care certification....more

Hospital Recovers Income Guarantee Payments from Suspended Physician

It should come as no surprise there are cases in which hospitals seek to and actually do recover income guarantee payments made to physicians whom, either through termination of employment or loss of hospital privileges, fail...more

CMS Releases Proposed 2015 Physician Fee Schedule and Projects 20.9% SGR Reduction

CMS has issued the Proposed 2015 Physician Fee Schedule and Fact Sheets for specific issues (ASC, ESRD, Home Health, Physician Quality Programs)....more

Medical Staff Bylaws Are Not Contracts in Delaware

One of the fundamental issues in credentialing disputes is whether the Medical Staff Bylaws constitute contracts between the Hospital and the individual physicians. If the Medical Staff Bylaws do constitute a contract, then...more

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