Health Law Alert

On November 30, 2015, the OIG posted an announcement of a settlement agreement with a skilled nursing facility company, Regent Management Services, L.P. The settlement amounted to approximately $3.199 million in order to resolve allegations that Regent received kickbacks from various ambulance companies in exchange for referrals of Medicare and […]

In September 2015, the U.S. Department of Health & Human Services Office of Inspector General (“OIG”) issued two studies concerning the Office for Civil Rights’ (“OCR’s”) oversight of compliance with the HIPAA rules. The first study recommends that OCR strengthen its oversight compliance with the HIPAA Privacy Standards. The second […]

On November 13, 2015, CMS published as a final rule its latest iteration of the 2-midnight rule, the standard for billing inpatient services under Part A of the Medicare program. As background, the 2-midnight rule was initially proposed by CMS in 2013, in response to two perceived issues: The Recovery […]

Over the years, the OIG has issued a number of advisory opinions regarding various proposals from hospitals to provide transportation for patients. Some have been found not to draw prosecution and sanctions and others have not fared so well. The typical contours of a transportation program that does not risk […]

CMS recently released final rules for the Electronic Health Records Incentive Program (“Meaningful Use”). The final rules include modifications for program years 2015 through 2017 and also include the Stage 3 objectives and measures for eligible hospitals (“EHs”), critical access hospitals (“CAHs”) and eligible professionals (“EPs”). CMS’ goal is to […]