CMS Finalizes Physician Payment Sunshine Regulations
In early February, the Centers for Medicare & Medicaid Services (CMS) issued regulations implementing the Physician Payments Sunshine Act, one of several Affordable Care Act mandates intended to...
View ArticleOIG’s Update to the Provider Self-Disclosure Protocol Offers Expanded Detail...
The updated Provider Self- Disclosure Protocol (SDP) issued April 17, 2013 by the OIG expanded and updated the original SDP issued on October 30, 1998 and the OIG's Open Letters to health care...
View ArticleA Continued Challenge: The 3-Day Payment Rule Timeline
The Centers for Medicare and Medicaid Services' 3-day and 1-day payment rules (the "Payment Rules") continue to generate many questions among health care providers and suppliers concerning effective...
View ArticleOIG Exclusion Update: The Who, What, When, Where, and Why
The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently released an updated Special Advisory Bulletin1 covering the scope and effect of exclusion from Federal...
View ArticleOIG Report Revives Debate over Critical Access Status
On August 15th, the Office of Inspector General (OIG) released a report sure to add fuel to the continuing debate over Medicare payments to rural providers: “Most Critical Access Hospitals Would Not...
View ArticleOFCCP: “TRICARE Providers Are Subject to Affirmative Action Requirements”
For years, we have been tracking the Department of Labor’s Office of Federal Contract Compliance Programs’ (“OFCCP”) efforts to expand its jurisdiction to health care employers. Generally, the OFCCP...
View ArticleCMS Provides Guidance on Enrollment and Certification During Mergers and...
On September 6, 2013, CMS issued a survey and certification letter to state survey agency directors that provides guidance on the automatic assignment of Medicare provider agreements in health care...
View ArticleCMS Revises Views on Denying Medicare Enrollment Based on Outstanding...
After rescinding proposed instructions on Medicare provider enrollment denials for applicants with outstanding overpayment liability earlier this year, the Centers for Medicare & Medicaid Services...
View ArticleOIG Advisory Opinion Provides Additional Guidance on Supplier's/Provider's...
Much confusion surrounds the issue of whether or not a Medicare supplier or provider may charge individuals or payors other than Federal health care programs less than its usual charges. A recent OIG...
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