Physician Compensation and Reimbursement
Polsinelli Podcast - Health Care Payment Changes: From Service to Value
On Oct. 25, 2023, the Office of Inspector General (OIG) for the Department of Health and Human Services (DHHS) issued an unfavorable opinion in response to a manufacturer’s proposal to offer and provide a free compatible...more
Below is Alston & Bird’s Health Care Week in Review, which provides a synopsis of the latest news in health care regulations, notices, and guidance; federal legislation and congressional committee action; reports, studies,...more
On September 30, 2021, OIG posted Advisory Opinion No. 21-14 regarding a chiropractor’s proposal to extend an existing discount program covering a package of services to include federal health care program beneficiaries. OIG...more
Report on Medicare Compliance 30, no. 8 (March 1, 2021) - According to a CMS spokesperson, “CMS has not yet determined when Targeted Probe and Educate reviews will resume.” Meanwhile, “CMS continues to temporarily pause...more
Regulation - CMS Contemplating Telemedicine Changes - The Centers for Medicare & Medicaid Services (CMS) recently published what it described as a "major proposed rule" that covers a number of topics that could have...more
The OIG added 12 new items to its Work Plan in the August 2018 update. Hot topics related to Centers for Medicare & Medicaid Services (CMS) oversight in this month's Work Plan include: state oversight of opioids; potential...more
Last week, the Department of Health and Human Services – Office of Inspector General (“OIG”) released a portfolio report identifying multiple vulnerabilities in the Medicare Hospice Program (the “Hospice Portfolio Report”),...more
Physical therapy providers are the target of a recent HHS Office of Inspector General (OIG) report that identified millions of dollars in overpayments for improperly billed Medicare services. The OIG selected a stratified...more
The OIG added three items to its Work Plan with the February 2018 update, as listed in the chart below. Two of the items concern annual reports, one addressing the performance of Medicaid Fraud Control Units and the other...more
We expect 2018 to be another year of rapid change within the health care industry. In this episode, Mary Beth Johnston highlights some of the key topics that the health care practice group will monitor in the coming year,...more
On Feb. 9, 2018, the Trump Administration released a 30-page report analyzing domestic and global factors influencing drug pricing. The report by the Council of Economic Advisers (CEA) is expected to inform the HHS' Fiscal...more
The OIG added six new items to its Work Plan with the January 2018 update, as listed in the chart below. Consistent with prior Work Plan missives, the OIG continues to focus its efforts on reducing prescription opioid misuse....more
The Situation: A Final Rule published by the Centers for Medicare & Medicaid Services carries a provision that reduces reimbursement for most 340B Program drugs dispensed by disproportionate share hospitals and rural referral...more
Earlier this month the House Energy and Commerce Committee’s subcommittee on Government Oversight and Investigations held its second hearing on the 340B Drug Discount Program. The hearing followed on the heels of a July 18th...more
In our July 10, 2017 post, Concierge Medicine – Is it for you?, we cautioned that Medicare compliance concerns do not fall away when moving to a concierge or direct-pay model. HHS has determined that concierge-style...more
In March, I posted about the Uncertain Future of the 340B Drug Discount Program. When opining about What Could Happen Next I speculated about possible changes to government reimbursement for 340B drugs “so that government...more
I. REGULATIONS, NOTICES, & GUIDANCE - On April 21, 2016, CMS issued a proposed rule entitled, “Medicare Program: FY 2017 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements.” This...more
Recent action by the Centers for Medicare and Medicaid Services (CMS) announces significant change in reimbursement methodology for high volume orthopedic surgical procedures in many markets nationwide. Affected stakeholders...more
Fraud, waste, and abuse in the Medicare Part D prescription drug program continue to threaten the integrity of the program and pose challenges to the federal agencies charged with its administration and oversight. Earlier...more
The Department of Health and Human Services Office of Inspector General (OIG) recently reported that Medicare contractors overpaid physicians $33.4 million in incorrectly coded physician services between January 2010 and...more
You have to admire the vigilance and dedication of prosecutors and law enforcement investigators who fight Medicare fraud. There is no question that they have ramped up enforcement and promoted a strong message of deterrence....more
The OIG recently released a report summarizing the details of its study regarding compliance with the requirement that physicians (or certain practitioners working with them) who certify beneficiaries as eligible for Medicare...more
On April 16, 2014, the OIG released a report concluding that between CYs 2007 through 2011, Medicare has saved nearly $7 billion by covering surgical procedures in ASCs. In addition to the savings that would continue to...more
In the final Medicare Physician Fee Schedule for 2014 (“2014 PFS”), CMS implemented a new condition of payment for “incident to” services that has significant fraud and abuse implications for any Medicare provider who relies...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