Michael R. Schulze

One obscure but sweeping provision of the Patient Protection and Affordable Care Act (“PPACA”) grants the Centers for Medicare & Medicaid Services (“CMS”) unchecked authority to impose administrative moratoria on new providers and suppliers without …..

The Centers for Medicare and Medicaid Services (CMS) issued a final decision as part of its review of appropriate supervision levels required for hospital outpatient services. The new rule, effective July 1, 2012, simplifies what …..

Novitas Solutions, Inc. (Novitas) recently issued two local coverage determinations (LCDs) that created significant compliance issues for hospital outpatient psychiatric departments. LCD L32705: Partial Hospitalization Programs (PHPs) – Psychiatric incorrectly requires “direct personal supervision” by …..

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After almost a year and a half of waiting, the Centers for Medicare & Medicaid Services (CMS) has issued settlement announcements for four providers under the federal Voluntary Self-Referral (Stark) Disclosure Protocol (SRDP). Despite a …..