Client Advisory: CMS Takes Action to Prepare Health Care Facilities to Respond to the Coronavirus (COVID-19) Threat

Introduction On March 4, 2020, CMS issued three new Quality, Safety, and Oversight memos intended to help ensure that America’s health care facilities are prepared to meet the threat posed by COVID-19. Two memos concerned suspension of survey activ… Read More
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Client Advisory: Coordinated Proposals of the CMS and OIG Proposed Rules to Amend the Stark, Anti-Kickback, and Civil Monetary Penalty Laws

The Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule on October 17, 2019 that would amend and provide new exceptions for certain value-based compensation arrangements under the physician self-referral law or Stark la… Read More
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Categories: Uncategorized

Client Advisory: Is this Notice and Comment? Provision Buried in Massive 2020 Physician Fee Schedule Rule Gives CMS New Ability to Revoke or Deny Medicare Enrollment Following State Board Disciplinary Actions

Introduction Effective on January 1, 2020, the 2020 Revisions to Payment Policies Under the Physician Fee Schedule provides numerous updates from the Centers for Medicare and Medicaid Services (“CMS”) concerning Medicare payment rates, documentat… Read More
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Categories: Client Advisory

Client Alert: Medicare Beneficiary Identifiers: The New, More Secure System for Medicare Beneficiaries

Starting January 1, 2020, all physicians, providers, and suppliers submitting claims to Medicare Administrative Contractors (MACs) for all services provided to Medicare beneficiaries, including Durable Medical Equipment, Home Health, and Hospice, mus… Read More
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Categories: Client Advisory

Client Advisory: Program Integrity Enhancements or Compliance Nightmare? Changes to Providers’ Affiliation Disclosure Requirements

On November 4, 2019, a new final rule went into effect that dramatically expands affiliation disclosure requirements for enrolling and revalidating providers and suppliers in Federal health care programs. The new rule enhances CMS’s authority to de… Read More
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Categories: Client Advisory

Client Alert: An Early Holiday Gift? The State Corporation Commission’s New Online Filing System

On December 9, 2019, the Virginia State Corporation Commission (“SCC”) launched a new online filing system. The new, modernized computer information system (“CIS”) will manage the Commission’s business entity and Uniform Commercial Code rec… Read More
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Categories: Client Advisory

Client Advisory: October 2019 Updates to the Nursing Home Compare Website and the Five Star Quality Rating System

On October 7th, 2019, CMS announced abrupt changes to the Five Star Quality Ratings System and the Nursing Home Compare website. The two changes are scheduled to go into effect on October 23, 2019 and include: 1) a conspicuous new warning icon to lab… Read More
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Categories: Client Advisory

Client Advisory: SAMHSA Proposed Rule Amends the Way Confidential Records of Substance Use Disorder Patients are Handled to Facilitate Better Coordination of Care

Introduction Part 2 of Title 42 of the Code of Federal Regulations imposes limits on “the disclosure and use of substance use disorder patient records which are maintained in connection” with a federally assisted program that “holds itself out… Read More
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Categories: Client Advisory

CLIENT ADVISORY: CMS Final Rule Permits and Regulates Pre-Dispute, Binding Arbitration Agreements in Nursing Facility Admission Agreements

A new Final Rule, effective September 16, 2019, revises Medicare’s Requirements of Participation (ROPs) to permit and regulate the use of pre-dispute, binding arbitration agreements in nursing facility admission agreements. Nursing facilities using… Read More
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Categories: Client Advisory

CLIENT ADVISORY: Drugs are hazardous to your…drinking water and budget: New EPA standards for wasting and managing pharmaceuticals go into effect this month

Introduction Attention hospitals, physician offices and nursing homes: there is a new regulatory requirement for drug disposal, requiring new standards, paperwork, and training for many facilities. The new rule published by the Environmental Protecti… Read More
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Categories: Client Advisory