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Estate Planning During Divorce (Part 2)
It pays to look closely. Buried deep within a 205-page and 1230-page Federal Register final rules publication, the Centers for Medicare & Medicaid Services (“CMS”) initiated impactful changes for pharmacies and Durable...more
Continuing a now annual tradition, the Centers for Medicare & Medicaid Services (CMS) has included expansions and enhancements to its authorities to deny enrollment or revoke a provider’s Medicare billing privileges...more
The Centers for Medicare & Medicaid Services (CMS) requires Medicare providers and suppliers to keep their enrollment information up to date at all times. Changes in this information can affect claims processing, payment...more
On June 30, 2020, Centers for Medicare and Medicaid Services (CMS) published a proposed rule that includes new provisions implementing the home infusion therapy (HIT) benefit category and outlines enrollment standards for HIT...more
CMS recently finalized the most significant changes to enrollment since the 2006 enrollment rules were initially adopted. Overview of the New Rule - In its "Program Integrity Enhancements to the Provider Enrollment...more
Yesterday, a final rule issued by the Centers for Medicare & Medicaid Services (CMS) establishing new enforcement initiatives aimed at removing and excluding previously sanctioned entities from Medicare, Medicaid, and the...more
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry. ...more
On September 5, 2019, the Centers for Medicare & Medicaid Services (CMS) announced a final rule expanding CMS’ authority to deny or revoke enrollment in the Medicare program as a result of “bad actor” affiliations. Providers...more
On September 5, 2019, the Centers for Medicare and Medicaid Services (“CMS”) released a final rule with comment period entitled, “Program Integrity Enhancements to the Provider Enrollment Process” (the “Final Rule”). The...more
The Centers for Medicare & Medicare Services (CMS) recently proposed sweeping changes that would permit the denial of a Medicare enrollment application or a billing privilege revocation for professionals eligible to...more
CMS revised its policy guidance regarding adverse action reporting requirements once again in the Medicare Program Integrity Manual (MPIM) Transmittal 865. This guidance is arguably inconsistent with the regulations and with...more
On June 1, 2018, CMS issued further guidance for reporting and reviewing final adverse legal actions (ALAs) in provider enrollment applications. In Transmittal 797, which replaces Transmittal 784 to the Medicare Program...more
Recently, we have noticed an alarming increase within the Spilman footprint of revocations by the Centers for Medicare & Medicaid Services ("CMS") of physicians' Medicare billing privileges. In particular, CMS has been...more
In 2014, CMS issued a final rule related to 42 CFR 424.535, which gave CMS expanded authority to impose penalties on providers. Although the rule is several years old, the first version published in 2006, the rule has been...more
The Centers for Medicare and Medicaid Services (CMS) has demonstrated that it will not hesitate to use one of its most crippling administrative enforcement tools—the revocation of Medicare billing privileges—against one of...more