Searching Content indexed under Healthcare by Christopher Janney ordered by Published Date Descending.
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New California Drug Pricing Initiative Could Significantly Impact 340B Providers
California Governor Gavin Newsom recently issued an executive order directing state agencies to consolidate their purchasing of drugs in an effort to increase the state's bargaining power and lower its drug spend.
United States
20 May 2019
Hospital System Pays $84.5 Million To Settle AKS And Stark Law Violations
In 2010 and 2011, four former employees of WBH in Detroit, Michigan filed separate lawsuits under the federal civil FCA and Michigan Medicaid FCA, alleging violations of the federal health care program AKS...
United States
16 Aug 2018
Can Value-Based Programs Work With Stark Law Limitations?
Like the federal health care program anti-kickback statute (AKS), the federal physician self-referral law (Stark Law) was designed for a different, largely fee-for-service world where the principal concern was physicians ...
United States
29 Jun 2018
Dear CMS: We'd Like Our Rabbit Back: The Case For Reinstating The Stark Law's Physician Payments Exception
The federal physician self-referral statute1 and its implementing regulations—commonly referred to as the "Stark Law" ...
United States
12 Mar 2018
CMS Moves Forward With Controversial Reductions In Medicare Reimbursement For 340B Drugs
On November 1, 2017, the Centers for Medicare & Medicaid Services (CMS) posted a display copy of its final rule regarding the Medicare outpatient prospective payment system (OPPS)...
United States
9 Nov 2017
CMS Publishes RADV Medical Reviewer Guidance
In the Medicare Advantage (MA) context, "risk adjustment" is the process by which the Centers for Medicare & Medicaid Services (CMS) reimburses Medicare Advantage Organizations (MAOs)...
United States
26 Oct 2017
Federal District Court Interprets Stark Law's "Writing" Requirement
On March 15, 2017, the US District Court for the Western District of Pennsylvania, ruling on cross motions for summary judgment in U.S. ex rel. Tullio Emanuele v. Medicor Associates Inc. et al.
United States
30 Mar 2017
HHS-OIG Issues Final Rules On Anti-Kickback And Civil Monetary Penalty Statutes
Earlier today, the US Department of Health & Human Services, Office of Inspector General issued two final rules.
United States
16 Dec 2016
HHS-OIG Increases Beneficiary Inducement CMP Nominal Gift Amounts From $10 To $15 Per Gift And $50 To $75 Per Year
The beneficiary inducement civil monetary penalty law generally prohibits health care providers from providing gifts to a Medicare or Medicaid beneficiary.
United States
14 Dec 2016
CMS Issues Final Overpayment Rule: A Guide On How To Eat An Elephant
Among the most critical issues facing providers and suppliers is determining when an overpayment is considered "identified" for purposes of triggering the 60-day report and return requirement.
United States
17 Feb 2016
CMS Finalizes Significant Stark Law Rulemaking
In July of this year, the US Department of Health & Human Services (HHS), Centers for Medicare & Medicaid Services (CMS) proposed significant changes to the regulations implementing the federal physician self referral law.
United States
9 Nov 2015
A Summary And Analysis Of HRSA's Proposed 340B Program Guidance
The net result of this informal regulation has been growing confusion on the part of both manufacturers and covered entities as to the precise contours of many of the program's most important components.
United States
3 Sep 2015
CMS Proposes Significant Changes To Stark Regulations
Many Stark Law regulatory exceptions require that the arrangement at issue have a term of at least one year.
United States
10 Jul 2015
DC Circuit Calls Into Question Legality Of Stark Law Ban On Per-Click Equipment Leases
On June 12, 2015, the US Court of Appeals for the District of Columbia Circuit issued a lengthy decision calling into question the regulatory prohibition on per-click equipment leases under the federal physician self-referral law.
United States
18 Jun 2015
HHS-OIG Issues Proposed Rule Relating To AKS, Beneficiary Inducement CMP, And Gainsharing CMP
The US Department of Health and Human Services, Office of Inspector General has promulgated a proposed rule that would amend some of the agency's regulations.
United States
3 Oct 2014
Stark Law Update: US Reaches Groundbreaking FCA Settlement With Hospital
A group of related corporate entities that collectively operate All Children's Hospital entered into a $7 million False Claims Act settlement with the U.S.
United States
30 Apr 2014
The Fraud And Abuse Elephant In The Room: Are ACA Exchanges Federal Health Care Programs?
Pursuant to the US Affordable Care Act, beginning January 1, 2014, certain individuals will be permitted to purchase "qualified health plans" through state exchanges.
United States
10 Jun 2013
HHS-OIG Recommends Providers Check Exclusion List Monthly
On May 8, 2013, the US Department of Health and Human Services, Office of Inspector General issued a "Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs" ("2013 Bulletin").
United States
19 May 2013
HHS OIG Issues Updated Provider Self-Disclosure Protocol
On April 17, 2013, the US Department of Health and Human Services, Office of Inspector General (HHS-OIG) released an updated provider self-disclosure protocol (SDP).
United States
23 Apr 2013
Congress Extends Overpayment Recovery Period
Among the many provisions buried in this week's 150+ page American Taxpayer Relief Act ("ATRA"), one — Section 638 — amends Section 1870 of the Social Security Act ("SSA").
United States
7 Jan 2013
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