The U.S. Attorney’s Office for the Eastern District of Pennsylvania recently announced several False Claims Act settlements and a new complaint against a Kansas chiropractor concerning allegations of improper billing for the use of certain P-Stim... Read More
Category: Value Based Care
The pandemic exposed, among other things, some of the shortcomings facing long-term care facilities. Being well-aware of the persistent issues long-term care facilities have with resources, the federal government nevertheless pushed for... Read More
Senior Counsel Theresa DiGuglielmo, Esq., whose regulatory healthcare practice includes work with Behavioral Health providers, recently interviewed James M. Tudor, CPC, PCA, Director of Billing Compliance for HealthCare Compliance Network... Read More
What’s Next? What to Expect in Post COVID-19 Government Oversight and Enforcement Actions for Long Term Care and Skilled Nursing Facilities.
As the nation reels from the heartbreaking COVID-19 pandemic, scrutiny of Skilled Nursing Facilities and Long-Term Care facilities is all but certain to continue. Industry leaders and recent data suggests providers anticipate enhanced oversight from... Read More
On April 26, 2021 the Office of Inspector General (“OIG”) in the U.S. Department of Health and Human Services (“HHS”) issued a new Advisory Opinion Letter providing its analysis as to whether a “Proposed Arrangement” involving an... Read More
Frier Levitt Secures Near Eight-Figure Settlement In Connection with Value-Based Care Contract Dispute
Physician groups contracting with government-regulated health plans such as Medicare-Advantage Organizations, Medicaid Managed Care Organizations, or ACA Marketplace Individual/Small Group Issuers often enter into capitated payment models with... Read More
PROVIDER ALERT: OIG Report Appears to Indicate that Medicare Advantage Organization, Humana, Inc. May Be Significantly Underpaying Downstream Contracted Providers in Global Risk Capitation Arrangements
Following the release of an April 16, 2021 HHS Office of Inspector General (“OIG”) report entitled “Medicare Advantage Compliance Audit of Diagnosis Codes that Humana, Inc. (Contract H1036) Submitted to CMS” (the “OIG Report”), headlines... Read More
The Department of Health and Human Services (HHS) recently published the long-awaited new rules related to the Anti-Kickback Statute, Civil Monetary Penalties Law, and the Stark Law (collectively, the “Final Rules”). The Final Rules are part of... Read More
CMS Has Invoked Its “Extreme and Uncontrollable Circumstances” Policy to Offer ACOs Some Degree of Relief During the COVID-19 Crisis – But What About Your Commercial Shared Savings Contracts?
In a March 30th, 2020 proposed Interim Final Rule (“IFR”), CMS declared that it would be applying (and, later, expanding the scope of) its “extreme and uncontrollable circumstances” regulation, 42 C.F.R. 425.502(f), to “mitigate any impact... Read More
Pharmacy, Physician Dispenser, and Wholesaler ALERT: OIG’s Safe Harbor Proposed Rule Potentially Excludes Pharmacies, Physician Dispensers, and Wholesalers as Value Based Entity Participants
Value Based Care is the future of the United States healthcare system and the Office of the Inspector General (OIG) for the US Department of Health and Human Services is in full agreement. The OIG recently issued a Notice of Proposed Rulemaking that... Read More