On December 18, 2015, the President signed into law Public Law No. 114-112 which provides a one-year extension, through 2015, of the enforcement moratorium on supervision requirements for outpatient therapeutic procedures at critical access hospitals (CAHs) and small rural hospitals. As a result, the Centers for Medicare and Medicaid Services […]
Health Law Alert
“Swapping” Arrangements—Now a Sword That Cuts Both Ways
on Monday, 21 December 2015 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
OIG Study Suggests Increased HIPAA Enforcement
on Monday, 14 December 2015 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
2-Midnight Rule Finally Final and Effective January 1, 2016
on Monday, 7 December 2015 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
Health System Free Shuttle Rides for Patients will Not Result in Sanctions
on Monday, 23 November 2015 in
Health Law Alert: Kristin N. Lindgren, Editor
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 […]
