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Please Click HerePosted on May 22, 2014 by Ruder Ware Alumni
A growing area of the health care legal practice involves counseling clients on issues that could require self disclosure under OIG or CMS procedures. The Office of Inspector General has procedures that a provider may follow to disclose possible violations of the Anti-Kickback Statute or other federal laws. Providers have the opportunity to avoid much […]
Posted on May 22, 2014 by Ruder Ware Alumni
As health care provider networks move down the path toward clinical integration, we are often asked to provide guidance on how information can be jointly provided to payors. The antitrust laws recognize that collective sharing of some pricing information, even by otherwise competing providers, can be beneficial and does not necessarily violate antitrust laws. However, […]
Posted on May 21, 2014 by Ruder Ware Alumni
The Centers for Medicare and Medicaid Services (CMS) issued a new proposed rule today that changes the timeline for meaningful use electronic health record (EHR) technology. The new proposed rule would be consistent with previous CMS announcement regarding extension of Stage 2 and Stage 3 timelines. The proposed rule recognizes the difficulties that software vendors […]
Posted on May 19, 2014 by Ruder Ware Alumni
On May 12, 2014, the Office of Inspector General (OIG) published a proposed rule that would amend the civil monetary penalty (CMP) rules of the OIG to incorporate new CMP authorities, clarify existing authorities, and reorganize regulations on civil money penalties, assessments, and exclusions. The proposed regulations are intended by the OIG to update regulations […]
Posted on May 19, 2014 by Ruder Ware Alumni
There are many organizations around the country that use a messenger model as a managed care contracting mechanism. Under the messenger model, an intermediary is used to shuttle offers from managed care organizations to individual providers who sign on to the network. Messenger model networks should not be confused with clinically integrated systems. Clinical integration […]
Posted on May 19, 2014 by Ruder Ware Alumni
One area it is relatively common to find compliance infractions involves the employment of individuals by a health care provider who may be listed on the list of parties who are excluded from federal health care programs. Most providers have integrated routine background checks and excluded party searches into their hiring program. Occasionally, an excluded […]