On February 13, 2015, the Office of Inspector General published Advisory Opinion 15-02, on the effect of exclusion from Medicare, Medicaid and all other Federal health care programs. The Opinion responds specifically to an inquiry as to whether payments for services performed by a physician and his/her medical practice prior […]
Health Law Alert
A Little More Time! CMS Extends Meaningful Use Attestation Deadline
On February 25, 2015, the Centers for Medicare and Medicaid Services (“CMS”) announced that Eligible Professionals (“EPs”) participating in the Medicare Electronic Health Record Incentive Program (“Meaningful Use”) now have until 11:59 p.m. ET on March 20, 2015, to attest to Meaningful Use for the 2014 reporting year. The previous […]
What are Compliance Plans and Why Do We Need Them?
Most health care entities have a compliance policy. However, in many cases, they don’t have compliance plans and are unaware of their usefulness. Compliance plans are detailed plans setting out standards for compliance in specific areas or with respect to particular issues. Compliance plans may be standing and ongoing or […]
Final § 501(r) Regulations Provide Community Health Needs Assessment and Corrective Guidance
Tax-exempt hospitals received a late-season present from the Department of the Treasury and the Internal Revenue Service after the agencies released long-awaited final regulations for requirements under the Patient Protection and Affordable Care Act (“ACA”). In addition to rules related to the provision of financial assistance and billing and collection […]
Tax-Exempt Hospitals: Final Financial Assistance and Billing and Collection Regulations Published
Background Section 9007 of the Patient Protection and Affordable Care Act created and added § 501(r) to the Internal Revenue Code (the “Code”). Section 501(r) put into place a number of significant new requirements that tax-exempt hospitals must satisfy in order to retain tax-exemption, including provisions related to financial assistance, […]