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Search OptionsHealth CareCMS Emergency Preparedness Final Rule Nears Implementation Date
Hurricanes Harvey and Irma have devastated our nation in recent weeks and significantly impacted health care facilities in the affected areas. To better address preparedness for disasters such as Hurricanes Harvey and Irma, the Centers for Medicare and Medicaid Services (“CMS”) issued the Emergency… Changes to Indiana Medicaid State Plan Affect 340B Reimbursement
A July 21, 2017 letter from CMS approves Indiana’s State Plan Amendment (“SPA”) 17-0002, which “proposes to bring Indiana into compliance with the reimbursement requirements in the Covered Outpatient Drug final rule with comment.”[1] In review of the approved SPA, one notable change emerges, and… CMS Site Visit Verification Process Completed by Hired Hand
A quick peek at CMS’ FY 2018 budget (and beyond) indicates that CMS is investing heavily in rules enforcement.[1] Encouraged by a Fraud Prevention System return on investment of $11.50 for every $1.00 spent[2], CMS sees enhanced enforcement as a critical means of keeping (and returning) financial… Public Notice Regarding Medicare Provider Agreement Terminations
As part of the August, 14, 2017 Inpatient Prospective Payment System (“IPPS”) Final Rule[1], the Centers for Medicare and Medicaid (“CMS”) revised the public notice requirements for Medicare provider agreement terminations. Previously, a Rural Health Clinic (“RHC”), Federally Qualified Health… United States Senate Narrowly Fails to Advance Health Care Reform Legislation
After months of negotiations, Senate Majority Leader Mitch McConnell failed to find enough Republican support to advance some form of health care reform legislation late last week. Accordingly, the Patient Protection and Affordable Care Act (“ACA”) continues to remain the law of the land, though… EMTALA Turns 30; CMS Enforcement and New Rules Require Hospitals' (and Physicians') Attention
Without surprise, not many hospital providers joined in the celebration of EMTALA’s recent 30th anniversary. A lack of shared joy notwithstanding, EMTALA remains as rigorous, nuanced, and enforced as when it was first enacted as part of the 1986 COBRA legislation. The broad requirements of EMTALA… As EHR Incentive Program Sunsets, OIG Identifies Overpayments to Eligible Professionals
A June 12, 2017, OIG report indicates that, between 2001 and 2014, CMS paid $730 million in electronic healthcare record (“EHR”) incentive payments to eligible professionals (“EPs”) who did not comply with Federal requirements for “meaningful use” of EHRs. In other words, the OIG believes these… CMS Issues Proposed Rule for Updates to the Quality Payment Program
On June 30, 2017, CMS published a proposed rule with changes and policy updates to the Quality Payment Program (“QPP”) for calendar year 2018. The QPP, established under the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”), includes two pathways for participation, the Merit Based… Implementation of Indiana's Opioid Prescribing Law
Indiana’s seven day script law for new patients, Senate Enrolled Act (“SEA”) 226, went into effect on July 1, 2017.[1] Under SEA 226, the general rule is as follows: A prescriber may not issue more than a seven day supply of an opioid if the prescriber is prescribing to an adult patient for the… HHS To Review Anti-Discrimination Rule That Applies Protections to Transgender Patients
A Texas District Court judge presiding over a lawsuit challenging a Federal Regulation that expands protections to transgender patients, among others (“Rule”) recently agreed to stay judicial proceedings while the Health and Human Services (“HHS”) agency reviews the Rule. The court had earlier… The Cost of Abandonment – Patient Records
The 120th Indiana General Assembly recently enacted legislation to revise Indiana Code (“IC”) 4-6-14 regarding abandoned health records. Under the current statute, the attorney general (“AG”) may take possession of, store, maintain, transfer, protect, or destroy health records that the AG… Failure To Have A Business Associate Agreement Could Be A $31,000 Mistake
FileFax, Inc. (“FileFax”) is a Business Associate of the Center for Children’s Digestive Health (“Center”). The Center is a small, for-profit healthcare provider with a subspecialty practice in pediatrics. Since 2003, FileFax stored inactive paper medical records that contained protected health… |
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