The U.S. Department of Justice (“DOJ”) recently issued revisions to its Justice Manual that soften the impact of the September 2015 “Yates Memo,” named after its author, then-Deputy Attorney General Sally Yates. The Yates Memo instructed federal prosecutors not to give a corporate defendant any credit for cooperation unless the […]
Health Law Alert
OCR Asks for Your Feedback: The Request for Information on Reducing Regulatory Burdens to Improve Care Coordination
On December 14, 2018, OCR issued a Request for Information (“RFI”) asking how HIPAA can be revised to better promote care coordination and value-based care while preserving privacy and security protections. The RFI is relatively short, and easily digestible. It categorizes its requests into four topic areas, asking more specific […]
2018 NPDB Guidebook Battens Down the Hatches of Resignations While Under Investigation
On October 26, 2018, a new version of the National Practitioner Data Bank Guidebook was published by the Health Resources and Services Administration (HRSA), replacing the prior version published in April 2015. As background, hospitals and other health care entities are required to report adverse clinical privileges actions to the […]
Provider-Based News
Two recent developments from CMS related to provider-based departments: Payment Rates for Off-Campus Provider-Based Hospital Departments Paid Under the PFS Section 603 of the Bipartisan Budget Act of 2015 changed the reimbursement source for certain items and services furnished by some off-campus hospital outpatient provider-based departments. The change was to […]
CMS Finalizes and Delays Proposed Changes to E&M Services Coding
In November 2018, CMS issued its final rule for the Medicare Physician Fee Schedule. In a previous article, we had summarized the changes to E&M coding that CMS had proposed in its July 27, 2018 proposed rule. In this final rule, CMS delayed until 2021 any changes to reimbursement for […]