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Office of Inspector General Clarifies Online Digital Platforms and Marketing Practices for Physicians

Posted by: Brandon W. Shirley and Robert A. Greising on October 8, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The Health and Human Services Office of Inspector General (“OIG”) recently published an Advisory Opinion (“AO 19-04”) concerning the use of online platforms for finding and booking physician appointments and physician marketing. While the OIG determined that the platform and payment structure...


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OCR Holds True to Right of Access Initiative with First Enforcement Action

Posted by: Stacy Walton Long and Alexandria M. Foster on October 8, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

Earlier this year, the Office of Civil Rights (“OCR”) at the U.S. Department of Health and Human Services (“HHS”) announced its Right of Access Initiative. The Right of Access Initiative promises to vigorously enforce the rights of patients to receive copies of their medical records without...


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Judge Strikes Down Payment Cuts For Outpatient Department Evaluation and Management Services

Posted by: Brandon W. Shirley and Meghan M. Linvill McNab on October 8, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

In a decision dated September 17, 2019, a Federal judge invalidated a 2018 Centers for Medicare and Medicaid Services (“CMS”) regulation that attempted to align Medicare Part B payments for Evaluation & Management (“E&M”) services in hospital outpatient departments (“OPD”) with the lower rates...


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CMS and OIG Online Sources Provide Important Updates Regarding Corporate Compliance

Posted by: Susan E. Ziel and Andrew W. Breck on September 17, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

Health care, and its many statutory, regulatory and industry “yardsticks” are ever-changing and require regular attention.  In order to stay close to the action, particularly with respect to matters concerning corporate compliance, there are at least three online sources to consider.  The first...


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INSPECT Requirements for Prescriber Delegates

Posted by: Stacy Walton Long and Alexandria M. Foster on September 17, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

The Indiana Scheduled Prescription Collection and Tracking (“INSPECT”) program is an online tool that maintains a clearinghouse of patient information for health care professionals. The INSPECT database limits access to certain individuals and entities including the following: health care...


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CMS Warns “Beware of the Company You Keep” In New Sanctions Rule

Posted by: Brandon W. Shirley and Meghan M. Linvill McNab on September 17, 2019

Court Decision Clears Way for Broader Use of Postnuptial Agreements

In a new rule effective November 4, 2019, the Centers for Medicare & Medicaid Services (“CMS”) expanded Federal and State authority to punish providers with a troubled history or for affiliating with “bad actors” (the “New Rule”). In announcing the New Rule, CMS Administrator Seema Verma...


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CMS Proposes New Rules Aimed at Reshaping Medicare Payment Policies

Posted by: Andrew W. Breck and Meghan M. Linvill McNab on August 27, 2019

On July 29th, CMS jointly released its Proposed Rules for the 2020 Medicare Physician Fee Schedule and 2020 Hospital Outpatient Prospective Payment System that would update Medicare payment policies aimed at increasing price transparency, improving quality, and reducing burdens on providers. ...


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