We are on the clock. As an industry, we have 75 days to comment on the rules published in the Federal Register this week about how the Stark Law is implemented....more
Every day, people rely on highly skilled professionals to recall from memory a litany of information which helps them assess conditions, use their judgment, and respond accordingly. It should come as no surprise then, that...more
The Centers for Medicare and Medicaid Services (CMS) has finalized Form CMS-10328 (the SRDP Form), a new OMB-approved information collection instrument that must be used by providers and suppliers utilizing the Stark Law...more
The Supreme Court of the United States in Universal Health Services, Inc. v. Escobar et al., weighed in on and embraced the implied certification theory of liability within the False Claims Act (FCA)....more
6/22/2016
/ False Claims Act (FCA) ,
False Implied Certification Theory ,
Federal Contractors ,
Health Care Providers ,
Implied Certification ,
Material Misrepresentation ,
Medicaid ,
Medicare ,
Mental Health ,
SCOTUS ,
Universal Health Services Inc v United States ex rel Escobar ,
Unlicensed Medical Providers
On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged...more
On June 9, 2015, the HHS Office of Inspector General (OIG) issued a Fraud Alert that cautions physicians about questionable medical directorship and office staff arrangements. [Alert available here]. In the Fraud Alert, the...more
Beginning Monday, July 14, 2014, the review, dispute and correction process outlined the National Physician Payment Transparency Program (also known as the "Sunshine Act") opens on CMS's Open Payments website. Physicians and...more
7/16/2014
/ Affordable Care Act ,
Centers for Medicare & Medicaid Services (CMS) ,
Health Insurance ,
Hospitals ,
Manufacturers ,
Medical Devices ,
Pharmaceutical Industry ,
Physicians ,
Prescription Drugs ,
Provider Payments ,
Reporting Requirements ,
Sunshine Act
In This Issue:
- Exclusion from Federal Health Care Programs
- The New Advisory Bulletin
- What Providers Should Know
- For More Information
- Excerpt from Exclusion from Federal Health Care...more
On January 7, 2012, the OIG posted Advisory Opinion No. 12-22 to address a co-management arrangement between a hospital and physicians that is designed to align incentives by offering compensation based on quality, service,...more