Blog

Department of Justice Brings HEAT to New Jersey in the Form of the Medicare Fraud Strike Force

On Monday, August 13, 2018, the United States Justice Department (DOJ) announced the formation of the Newark/Philadelphia Regional Medicare Fraud Strike Force (Regional Strike Force), a successor to the Health Care Fraud Prevention & Enforcement Action Team (HEAT). The HEAT Strike Force has been focusing its efforts on 10 cities across the United States including Miami, Los Angeles, Detroit, Houston, Brooklyn, Baton Rouge, New Orleans, Tampa, Chicago, and Dallas. The...

CLIENT ALERT: Compliance with New Jersey’s New Out-of-Network Law

On June 1, 2018, New Jersey Governor Phil Murphy signed the "Out-of-network Consumer Protection, Transparency, Cost Containment and Accountability Act" into law.  The law contains a number of provisions which will have a serious impact on all licensed New Jersey healthcare providers, as well as healthcare facilities such as Ambulatory Surgical Centers (ASCs). Many medical practices and healthcare facilities have excellent internal controls ensuring that patients understand their financial commitments,...

The OIG Issues Report on Questionable Billing for Compounded Topical Drugs in Medicare Part D

The Office of the Inspector General for Health and Human Services (OIG) recently issued a report addressing payment for compounded topical medications by the Medicare D program. The report provides a roadmap for law enforcement, insurance companies, professional boards and pharmacy benefit managers (PBM) to investigate both pharmacies and prescribers. The report confirms long held concerns about particular activities and is a harbinger of future enforcement actions. The OIG evaluated...

Frier Levitt Succeeds in Challenging PBM Audit Based on Services Inadvertently Billed to Deceased Patients

Frier Levitt recently assisted an independent pharmacy with a PBM audit in which the Pharmacy Benefit Manager (PBM) alleged that the pharmacy had billed several claims to four beneficiaries who were deceased on the date of service for the claim. The PBM advised that if the pharmacy did not demonstrate the appropriate billing of those prescriptions, the claims would be reversed, and the full amount previously paid on each of...

Implications of (Not) Billing for Telemedicine

Telemedicine can be a means of providing high quality care in a way that increases access for patients and reach for providers while lowering cost for all parties involved. Although this seems like a winning proposition, telehealth is still in its infancy. Both regulators and payors acknowledge the potential cost savings and enhanced patient outcomes that may result from the expansion of telehealth; but they also acknowledge—and are attempting to...