Articles
OCR Begins Phase 2 of its HIPAA Audit Program
The U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) has begun its second phase of audits (Phase 2 Audits) of compliance with Health Insurance Portability and Accountability Act of 1996 (HIPAA) …..
Automatic Denial Authority for “Related claims”
CMS Provides MACs, CERT, RACs, and ZPICs with Automatic Denial Authority for “Related claims” Effective March 6, 2014, CMS amended the Medicare Program Integrity Manual giving MACs, RACs, CERT contractors, and ZPICs discretion to automatically …..
Sixth Circuit Dismisses Racial Discrimination Claim by Surgeon Following Suspension of Privileges
For Brintley to prevail on her state-law racial discrimination claim, the appeals court observed that the lack of any direct evidence that St. Mary’s discriminated against her on the basis of her race required Brintley …..
Physician Owned Hospitals Must File Annual Report by December 1, 2013 to Comply with Stark II
The Centers for Medicare & Medicaid Services (“CMS”) defines hospitals with physician owners or investors as Physician Owned Hospitals. Physician Owned Hospitals utilizing the Stark II whole hospital and rural provider exceptions must now file …..
The Affordable Care Act and Closing the Prescription Benefit Coverage Gap
(“Doughnut Hole”) Medicare Part D Coverage Gap Under the Medicare Part D Prescription Drug Benefit, many Medicare beneficiaries have annually encountered a large gap in their prescription drug coverage that is commonly referred to as …..
Hospital-Physician Employment Agreements: Sorting through the Aftermath of the Tuomey Decision
It is critically important for hospitals to be especially vigilant about complying with Federal and state fraud and abuse statutes in relation to the Hospital’s financial arrangements with physicians. A jury in a Federal trial …..