News & Analysis as of

Proposed Rules Billing

Esquire Deposition Solutions, LLC

Who Should Benefit from AI in Depositions: The Client, the Law Firm, or Both?

The American Bar Association’s suggestion last year that it would be ethically problematic for lawyers to charge high fees for formerly time-intensive work made easy by generative artificial intelligence has prompted an...more

Lerman Senter PLLC

FCC Proposes Rules to Curb Cable Operator, DBS Provider Fee Practices

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The FCC has issued a Notice of Proposed Rulemaking (NPRM) to consider prohibiting certain billing practices of cable operators and direct broadcast satellite (DBS) providers. Specifically, the FCC is proposing to ban cable...more

McDermott+

Departments Propose Broader Batching and IDR Process Changes for Surprise Billing Claims

McDermott+ on

On October 27, 2023, the US Departments of Health and Humans Services, Labor and the Treasury (the Departments), along with the Office of Personnel Management, issued a proposed rule titled Independent Dispute Resolution...more

McCarter & English, LLP

Slow and Steady Wins the Race: Hospitals Should Evaluate Their Split/Shared Services Notwithstanding the Delay Under CMS’s 2024...

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In the CY 2024 Physician Fee Schedule Proposed Rule (the Proposed Rule), the Centers for Medicare & Medicaid Services (CMS) proposed a further delay in implementing its time-only definition for determining the “substantive...more

Bradley Arant Boult Cummings LLP

CMS Proposes to Continue Allowing Remote Supervision Through December 31, 2024

In its Calendar Year (CY) 2024 Physician Fee Schedule (PFS) proposed rule, the Centers for Medicare and Medicaid Services (CMS) proposes to continue to allow supervising physicians and practitioners to conduct “direct...more

King & Spalding

CMS Issues Outpatient Prospective Payment System Proposed Rule for CY 2024

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On July 13, 2023, CMS published a proposed rule to update the payment policies, payment rates, and other provisions for services furnished under the Medicare Outpatient Prospective Payment System (OPPS) and the Ambulatory...more

Hinch Newman LLP

FTC Compliance Attorney Discusses Agency’s Dramatic Proposed Updates to Recurring Subscriptions and Memberships

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The Federal Trade Commission recently announced a proposed a “click to cancel” provision requiring sellers to make it as simple for consumers to cancel their enrollment as it was to enroll. According to the FTC, if...more

McDermott Will & Emery

CMS Proposes New Regulation to Clarify Physician and NPP “Split (or Shared)” Billing Policy

McDermott Will & Emery on

On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) released the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) proposed rule (Proposed Rule). The Proposed Rule sets forth CMS’ plans to revise...more

Holland & Hart LLP

HIPAA, Patient Access, and Designated Record Sets

Holland & Hart LLP on

With limited exceptions, HIPAA generally gives individuals the right to access or obtain copies of their protected health information ("PHI") from covered entities. (45 CFR § 164.524(a)). But the right of access does not...more

Foley & Lardner LLP

HIPAA Right of Access Initiative: 2020 Year in Review

Foley & Lardner LLP on

In 2020, the Office for Civil Rights (OCR) kept the promise it made the prior year to “vigorously enforce” the rights of patients to access and exercise control over their medical records. OCR has settled ten “right of...more

Dorsey & Whitney LLP

Reimbursement for Remote Patient Monitoring Services in 2019

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Medicare reimbursement for remote patient monitoring has taken a number of steps forward throughout this year. New and proposed rules from the Centers for Medicare and Medicaid Services both expand the billing options...more

Sheppard Mullin Richter & Hampton LLP

Take-Aways from CMS’ Recent Listening Session Regarding E/M Services: Documentation Guidelines and Burden Reduction

On March 21, 2018, a representative from the Hospital and Ambulatory Policy Group at the CMS, held a listening session regarding proposed updates to documentation guidelines for Evaluation and Management (“E/M”) Services. The...more

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