The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued a short fraud alert to individuals and facilities warning of a new scam. HHS OIG has been impersonated by scammers who represent themselves as HHS OIG representatives in an attempt to collect personal information from […]
Health Law Alert
New CMS Advice to CAHs Adding a Provider-Based Location
A new publication by CMS’s Quality, Safety and Oversight Group Director seeks to coordinate two important steps prior to the addition of any new practice location for a critical access hospital (CAH). This is intended to emphasize the requirement for CAHs that any new provider-based location located off-campus is more […]
October 2019 Was Full of Tricks, Not Treats, from the Office for Civil Rights
October was a busy month for the Office for Civil Rights (“OCR”) as it handed down one settlement and one civil monetary penalty for HIPAA violations and secured corrective action in a third case involving allegations of discrimination. With each enforcement announcement, OCR continues to send a message to health […]
CMS/OIG Issue Long Anticipated Stark and Anti-Kickback Proposed Rules
For quite some time, many in the industry have anticipated new rulemaking from CMS and the OIG related to the Stark law and the Federal Anti-Kickback Statute. Furthering the “Regulatory Sprint” to care coordination and value-based care, the agencies have delivered. In a coordinated effort, on October 17, 2019, CMS […]
Changes to CMS Enrollment and Enforcement Authority Designed to Close Loopholes for Bad Actors
On September 10, 2019, CMS published a Final Rule called Program Integrity Enhancements to the Provider Enrollment Process (CMS-6058-FC) with a comment period to be effective November 4, 2019. In previous enrollment changes establishing higher scrutiny for some provider/supplier types, CMS expressed its goal of stopping the “pay and chase” […]