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” […]
Health Law Alert
‘Site-Neutrality’ Policy is Thrown Out by Federal District Court
on Wednesday, 2 October 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
On September 17, 2019, US District Judge Rosemary Collyer of the District of Columbia struck down CMS’ policy included in the CY2019 Outpatient Prospective Payment System (OPPS) rule that cut Medicare payment rates to hospitals offering physician services. The policy established payment for medical services provided in off-campus, hospital outpatient […]
OCR Announces First Individual Right of Access Enforcement Action
on Wednesday, 2 October 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
Earlier this year, the U.S. Department of Health and Human Services, Office for Civil Rights (OCR) announced that it would vigorously enforce the rights of patients to receive copies of their medical records in a timely fashion. OCR held true to its word, and, on September 9, 2019, announced the […]
Proposed Update to Regulations on the Confidentiality of Substance Use Disorder Records
on Thursday, 5 September 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
On August 26, 2019, HHS’s Substance Abuse and Mental Health Services Administration (“SAMHSA”) published a Proposed Rule updating the regulations on the Confidentiality of Substance Use Disorder Records (“Part 2”). Part 2 Programs, which can be stand-alone facilities or individuals or departments of general medical facilities whose primary function is […]
The Evolution of Price Transparency Requirements for Hospitals in the FY 2020 Medicare Proposed Outpatient Prospective Payment Rule
on Thursday, 5 September 2019 in
Health Law Alert: Kristin N. Lindgren, Editor
The Centers for Medicare and Medicaid Services (“CMS”) issued a controversial proposed rule regarding price transparency for hospitals as part of the FY 2020 Outpatient Prospective Payment Proposed Rule. In its fact sheet regarding these provisions of the proposed rule, CMS noted that President Trump signed an Executive Order on […]
