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»  Posts By   February 2019 

What Providers Need to Know About NJ DOBI Bulletin NO. 18-14 on the Out-of-Network Act

The New Jersey Department of Banking and Insurance (DOBI) recently released a guidance bulletin, Bulletin NO. 18-14  (the "Bulletin"), in an effort to provide additional guidance to carriers, health care providers, and other interested parties in order to help those entities meet their obligations under the Out-Of-Network Consumer Protection, Transparency, Cost Containment, and Accountability Act, P.L. 2018, c. 32 (codified at N.J.S.A. 26:2SS-1 to -20), (the "Act"). While the Bulletin...

Frier Levitt 2018 Regulatory Liability Annual Report

In 2017, Frier Levitt formed a practice group to defend healthcare providers against a variety of regulatory and billing liabilities that have become all too commonplace in healthcare delivery today. 2018 represented our first full year of gathering data, and we are pleased to reveal our results.   We have seen troubling new trends, such as payors alleging billing fraud (without "intent") to increase the lookback period for potential recoupment. We...

Pharmacies Must Use Caution When Dealing with Third Party Auditing Companies

Over the past few years, PBMs have increasingly hired third party companies – such as SCIO, Xerox, Conduent or others – to conduct pharmacy audits. Many times, these companies are compensated based on the amount of money they recoup on behalf of the PBM (thus, they are incentivized to find as many discrepancies as possible). They are given very little training and certainly are not made aware of applicable audit...

Prime Therapeutics Continues Efforts Against Physician Dispensing

A year ago, Prime Therapeutics (Prime) announced that it would no longer accept new Physician Dispensing entities into their pharmacy networks starting on or around January 29, 2018. At the time, Prime had not terminated any Dispensing Physician entities that were already participating providers in its pharmacy networks and had made overtures that their participation would remain unaffected. Many Physician Dispensing entities nevertheless braced for aggressive audits and investigations, out...