New Guidance on Contractor Self-Disclosure

The Health and Human Services (HHS) Office of Inspector General (OIG) provides health care providers an opportunity to disclose potential violations of certain Federal civil and criminal laws in relation to HHS contracts or subcontracts, pursuant to which OIG offers a means for facilitated resolution. A new publication issued by OIG offers guidance on completing the self-disclosure form, and has been posted alongside an FAQ on the protocol.[1]

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CMS Care Coordination Payments – A Boon to Doctors and Patients but Patient Participation Will be Essential

As the Affordable Care Act continues to mature, we are seeing new efforts by the Obama administration to incentivize care coordination across a spectrum of services provided to Medicare Fee-for-Service (FFS) patients.  A New York Times article posted on August 16, 2014 reports that starting in January of 2015 Medicare will begin making monthly payments to physicians who manage care for patients with two or more chronic conditions like heart disease, diabetes and depression.  The Times reports that approximately two-thirds of Medicare patients suffer from two or more chronic conditions.  The program aims to incentivize physicians to improve medical outcomes, reduce hospital visits and readmissions and engage in preventative care.  Physicians will assess patients’ medical, psychological and social needs; monitor adherence to medication prescriptions and care provided by other doctors; and make arrangements to ensure a smooth transition when patients move from a hospital to post-acute care facilities or home-care.

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Bundled Payments under the Affordable Care Act Continue to Gain Influence

The Center for Medicare and Medicaid Services (CMS) recently announced that it will add roughly 4,100 providers to the 2,400 existing providers testing the possible use of Medicare bundled payment contracts.  Providers must apply to be candidates, and this group of now roughly 6,500 providers, including both hospitals and medical groups, will participate in analyzing Medicare spending data to assess possible bundled payment options.  This all comes as part of the Bundled Payments for Care Improvement initiative (BPCI), just one of the Affordable Care Act’s many attempts to incentivize health care providers to be more cost efficient.

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New York’s Health Information Highway – SHIN-NY – Get Involved as it Gets Rolling

The Statewide Health Information Network  of New York , also referred to as SHIN-NY, is a State-sponsored secure database network that is intended to house patient records, clinical data as well as other critical health care information across the State.  The network is designed to be an “information highway” which will enable New York clinicians and patients access to a comprehensive medical record and supplementary functions from virtually any location.[1] After several years of slow progress, the project is finally gaining momentum.

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Highlights from the Senate Special Committee on Aging’s Hearing on Medicare Observation Status

A recent Senate Special Committee on Aging hearing focused on the impact of Medicare observation status, a hospital outpatient designation for which Medicare covers fewer services and generally reimburses for services at a lower rate compared to inpatient care.[1]

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Tying health spending to the economy: What does it mean for the future?

Politicians, researchers, and other stakeholders have long recognized the importance of a slowdown in health spending in the U.S. Optimistically, the nation’s health spending has experienced a record slow growth rate in recent years, and the Congressional Budget Office (CBO) recently revised Medicare spending estimates downwards, albeit slightly. A recent article published in the Journal of the American Medical Association (JAMA) explores the trend and asks: Is it sustainable?[1]

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OIG issues Special Fraud Alert on laboratory payments to referring physicians

The Health and Human Services Office of the Inspector General (OIG) recently issued a Special Fraud Alert on laboratory payments to referring physicians.[1]  Specifically, the alert is concerned with Specimen Processing Arrangements and Registry Arrangements, which OIG believes pose substantial risks of fraud and abuse under the federal anti-kickback statute.

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CMS seeks to update payment rates and eligibility certification requirements in proposed rule for Medicare home health services

On July 7, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule updating Medicare’s Home Health Prospective Payment System payment rates for 2015.[1]

The rule implements the second phase of a four-year initiative to rebase Medicare home health payments. Specifically, the national, standardized 60-day episode payment amount, the national per-visit rates and the Non-Routine Medical Supply conversion factor are targeted for adjustments. The adjustments are intended to reflect changes in the cost and utilization of services such as the number of visits and mix of services provided in an episode, the level of intensity of services provided, and the average cost of providing care per episode.

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Top 5 Actions to Consider for the New York Not-for-Profit Law Overhaul Effective on July 1

On July 1, 2014, the New York Nonprofit Revitalization Act (the “Act”) took effect.  The Act is the most significant modification of New York’s Not-for-Profit Corporation Law (the “NPCL”) in approximately 40 years.

New York not-for-profit corporations that have not already fully considered actions that are necessary to comply with or to take advantage of the Act should do so now. 

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High Rates of Unhealthy Enrollees in ACA Exchanges

Perhaps putting added pressure on insurers as they prepare to set rates for 2015, new evidence suggests that people enrolled in health plans under the Affordable Care Act have higher rates of serious health conditions than those with other coverage. As The Wall Street Journal reported, this analysis comes from health-technology firm Inovalon Inc, which examined medical claims of those enrolled in the health law’s exchanges in the first quarter of this year.

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