On December 5, 2016, the OIG posted Advisory Opinion No. 16-12 concerning a laboratory’s proposal to provide the labeling of test tubes and specimens free of charge to dialysis facilities. One of the stated purposes of offering this free service was…
We previously published an article regarding the CMS proposed rule (published July 17, 2015) to revise the requirements that Long-Term Care (“LTC”) facilities must meet to participate in the Medicare and Medicaid programs, and its proposed changes…
St. Joseph Health (“St. Joseph”), a nonprofit Catholic health care delivery system, purchased a new server to store files, including electronic Protected Health Information (“ePHI”), that incorporated a file sharing application. The default settings…
On September 8, 2016, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Emergency Preparedness Rule (Final Rule”) for health care facilities. CMS has given significant attention to the Final Rule in light of the many major…
Medicare Access & CHIP Reauthorization Act of 20151
On April 27, 2016, the Centers for Medicare and Medicaid Services (“CMS”) issued a Notice of Proposed Rulemaking to implement parts of the Medicare Access & CHIP Reauthorization Act of…
The Franciscan Alliance and Christian & Medical Dental Associations joined six states in a lawsuit filed against Health and Human Services (“HHS”) in a Texas federal court on August 23, 2016, challenging the regulations that the HHS’ Office of Civil…
On July 17, 2015, CMS released a proposed rule to revise the requirements that Long-Term Care facilities must meet to participate in the Medicare and Medicaid programs. The proposed rule included a requirement regarding binding arbitration…
As many of you may know, the statewide home health reimbursement rates for Indiana Medicaid, are calculated based on the most recently completed Medicaid cost reports required from all home health providers billing Indiana Medicaid for services. (…
The Balanced Budget Act of 2015 (“BBA”) passed on November 2, 2015 provides that, effective January 1, 2017, “applicable items and services” (other than items and services furnished by a dedicated emergency department) furnished by an off-campus…
The Health and Human Services’ Office of Civil Rights (“OCR”) recently published a final Regulation (“Regulation”) that implements the nondiscrimination requirements of Section 1557 of the Patient Protection and Affordable Care Act.[1] Beginning on…
Following up on a previous client alert item, a federal jury recently found W. Carl Reichel, former president of Warner Chilcott, not guilty on June 17, 2016 of conspiring to pay kickbacks to doctors in exchange for writing prescriptions. The jury…
The Indiana General Assembly passed legislation during the 2015 General Session directing certain boards to establish protocols and standards for prescribing controlled substances for pain management treatment that “complement” existing rules for…
