OIG Issues Unfavorable Advisory Opinion Related to Fee Arrangement

Earlier this week the OIG issued an unfavorable Advisory Opinion concerning the relationship between an Anesthesiology Group (defined as the “Requester” in the OIG opinion), a Psychiatry Group and a Hospital.  The Psychiatry Group performed … [Continue reading]

Joint Commission Standards for Boarding and Leadership Collaboration with Behavioral Health Community

Effective January 1, 2014, hospitals, accredited by the Joint Commission, will be required to meet the elements of performance (EPs) related to boarding and leadership collaboration for behavioral health patients, as part of The Joint Commission’s … [Continue reading]

Proposed CN Rules on Hospital Change of Control & Transparency

The Washington State Department of Health recently released its proposed rules and letter to Governor Inslee with regard to his directive to open rule making on the Certificate of Need ("CN") hospital change of control regulations and transparency. … [Continue reading]

OIG Okays Provision of Free Services to Uninsured and Underinsured Patients

On October 15, 2013, the Office of Inspector General (OIG) released an Advisory Opinion concerning a community health services organization’s provision of free dental care to financially needy uninsured and underinsured patients that are not covered … [Continue reading]

Reducing the Risks of Third-Party Access to EHR Systems

UnityPoint Health, a health system located in Iowa, recently informed 1,800 patients of a breach of their health information.  UnityPoint learned of the breach after an audit discovered that a third party contractor’s employee had improperly gained … [Continue reading]

FDA Releases Guidance For Medical Mobile Apps

The Food and Drug Administration (FDA) recently released guidance on how the agency intends to regulate mobile applications (“mobile apps”).  This more complete guidance follows the FDA’s May 21“It has come to our attention” letter to Biosense … [Continue reading]

Guidance on Refill Reminders and Enforcement Delay until Nov. 7th

The Office of Civil Rights recently released guidance related to the new HIPAA marketing requirements and refill reminders.  The guidance includes several FAQs and examples to help navigate the new HIPAA marketing/refill reminder rules.  In … [Continue reading]

Want to Get Paid for Inpatient Admissions? Follow CMS Certification Requirements.

In its final regulations for the 2014 Inpatient Prospective Patient System, the Centers for Medicare and Medicaid Services emphasized the importance of physician certifications. Under the regulations, Medicare will only pay for an inpatient admission … [Continue reading]

Public Hospital Districts Offering Maternity Services Must Offer Abortion Services

A recent Washington Attorney General Opinion concludes that a public hospital district may not administer or fund programs to provide maternity care benefits or services without making provision for abortion services, benefits, and information.  The … [Continue reading]

OIG Approves Venture Spawned by CMS Hospital Readmission Penalties

In a recent Advisory Opinion, the OIG approved a business venture intended to reduce preventable hospital readmissions by providing post-discharge services to patients.  The venture would sell a package of services to hospitals intended to better … [Continue reading]