In December, the Office of Inspector General (OIG) launched a webcast series on provider compliance. Currently there are six short (approximately five minutes) webcasts on topics such as fraud and abuse, the anti-kickback statutes and the physician … [Continue reading]
ACO Application Requirements and Procedures
December 20, 2011 By
The final ACO regulations outline the process and required content for ACO applicants to participate in the Shared Savings Program. For the initial applications in 2012, the required term of the agreement will be either (i) April 1, 2012 through … [Continue reading]
ACO Final Rule – Drastically Reduces Quality Measure Requirements
December 8, 2011 By
The Accountable Care Organization (“ACO”) final rules show that comments to CMS really do make a difference. The public outcry against the 65 quality measures proposed in the spring led to CMS’ 50% cut of the number quality measures. Along with the … [Continue reading]
Stage 2 Meaningful Use – Delayed to 2014
November 30, 2011 By
HHS announced today that eligible professionals ("EPs") and hospitals who begin participating in the EHR Incentive Program in 2011 will not have to meet the Stage 2 Meaningful Use standards until 2014. Therefore, those EPs and … [Continue reading]
The Nuts and Bolts of Determining Shared Savings and Losses for ACOs.
November 28, 2011 By
Under the final rules released by CMS on Accountable Care Organizations (“ACOs”), CMS offers ACOs the opportunity to participate in one of two models -- a shared savings only model during the duration of the ACO’s first agreement period (Track 1), or … [Continue reading]
ACO Fraud and Abuse Law Waivers
November 23, 2011 By
In conjunction with the issuance of the final rules related for Accountable Care Organizations (“ACOs”) under the Medicare Shared Savings Program, the OIG published an interim final rule establishing waivers to fraud and abuse laws in connection with … [Continue reading]
ACO Antitrust Guidance
November 21, 2011 By
In coordination with CMS publishing the final Accountable Care Organization (ACO) regulations, the federal antitrust agencies issued a Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare … [Continue reading]
Ruling Halts Washington State’s Medicaid Emergency Room Visit Limit
November 18, 2011 By
A recent judicial decision has prevented the State’s implementation of a controversial policy that would limit payment for Medicaid patients to three “non-emergency” visits to emergency departments each year. The State asserted that implementation … [Continue reading]
New OIG Advisory Opinion – Pediatric Hospital May Provide Housing, Meals, etc.
November 16, 2011 By
Yesterday, the OIG issued Advisory Opinion No. 11-16 regarding the provision by a pediatric hospital of housing, transportation, meals and other miscellaneous items to patients participating in clinical research protocols. The OIG determined that … [Continue reading]
CMS Releases Final Rule on Accountable Care Organizations
November 7, 2011 By
On October 20, 2011, the Centers for Medicare and Medicaid Services (CMS) released its final rule on Accountable Care Organizations (ACOs), also known as the Medicare Shared Savings Program (the “Program”), enacted as a part of the Patient Protection … [Continue reading]
