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ENROLLMENT: A NEW ENFORCEMENT TOOL?
On December 3, 2014, CMS issued its Final Rule that addresses provider enrollment. These new rules create new tools to police provider enrollment. CMS now has the ability to deny enrollment of...
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New Rule on Medicare Reimbursement for Chronic Care Management Services
In November 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued a final regulation with changes intended to ensure Medicare’s payment system “reflect[s] changes in medical practice...
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CMS Rule on Medicare Overpayments? Don’t Hold Your Breath
Since the Center for Medicare & Medicaid Services proposed a rule three years ago suggesting that providers could be liable for returning Medicare overpayments going back ten years, providers have...
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Five Key Elements of Transitional Care Management
Similar to rules providing billing opportunities for chronic care management (as discussed in this McBrayer blog post), relatively new Medicare funds for Transitional Care Management (“TCM”) provide a...
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Time to Exclude the IMD Exclusion
Some rules are borne out of the best of intentions, and the Institutions for Mental Disease Exclusion (“IMD exclusion”) bears the hallmarks of such a beginning. The IMD exclusion bars federal funding...
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What changes are in store with the new CMS Proposed Rule for Medicaid managed...
On June 1, 2015 the Centers for Medicare & Medicaid Services (“CMS”) issued a proposed rule, revising the provisions of the Medicaid managed care (“MMC”) program for the first time in over twelve...
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CMS Proposes Sweeping Changes for Nursing Home Oversight
On July 16, 2015, the Center for Medicare and Medicaid Services (“CMS”) published a Proposed Rule with new standards that will have a sweeping effect on the long-term care industry. This new Rule is...
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CMS Sends a Lifeline on Stark after Tuomey Affirmed: What Health Providers...
In July, the Court of Appeals for the Fourth Circuit upheld a record verdict of $237 million against Tuomey Healthcare Systems in the case of U.S. ex rel. Drakeford v. Tuomey Healthcare System, Inc....
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Providers Wary after First Ruling on 60-Day Rule
The False Claims Act (“FCA”) is already a minefield for healthcare providers, especially when coupled with the Stark Law. Treble damages and fines of up to $11,000 per violation add up quickly under...
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Tidbits and Takeaways from OIG’s 2016 Work Plan
The Office of Inspector General for Health and Human Services (“OIG”) recently issued its 2016 Work Plan, which sets the agenda for its auditing and investigation in the year ahead. The broad mandate...
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