Health Law Alert

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 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 […]

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 […]

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” […]

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 […]