In OIG Advisory Opinion No.12-10, the OIG approved a radiology provider’s provision of free pre-authorization services to referring sources. The provision of free or discounted services to referral sources implicates the Federal Anti-Kickback... Read More
Horizon Blue Cross/Blue Shield of New Jersey has wrongfully terminated, and continues to systematically terminate, individual radiologists’ Provider Agreement. Horizon claims to be doing this in order to effectuate its policy of contracting with... Read More
Has your reimbursement for compounds been drastically reduced by Prime Therapeutics following the transition from NCPDP 5.1 to D.0? Prime requires pharmacies to submit all compound ingredients at the point-of-sale (“POS”). Prime does not usually... Read More
Alaska's State Medicaid agency (the “Agency”), has agreed to pay the U.S. Department of Health and Human Services’ (“HHS”) $1,700,000 to settle potential violations of the Health Insurance Portability and Accountability Act of 1996... Read More
Late last month, the United States Department of Justice announced that Walgreens Pharmacy had agreed to pay $7.9 million to settle allegations that Walgreens had violated the Federal False Claims Act. In a suit brought as a qui tam action by a... Read More
On June 13, 2012, the OIG issued a report following its review of four contractors that processed claims for test strips and/or lancets. The report concludes that the Medicare contractors improperly allowed for payment of a total of approximately... Read More
The United States Department of Health and Human Services Office for Civil Rights (OCR) has stepped up enforcement of the compliance requirements contained in the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and has begun... Read More
The OIG recently issued an Advisory Opinion Letter to an anonymous pharmacy that relates to a hot-topic Pharmacy Law Issue—Copayment Assistance. The OIG advised that it would not take any action against the pharmacy for a “proposed... Read More
A pharmacy owner recently lamented that she experienced a sudden and significant reduction in reimbursement rates for compounds dispensed to patients whose insurance coverage had not changed. The decrease in reimbursement began immediately after a... Read More
We see a significant “chatter” within our pharmacy client base regarding copay reimbursement programs. The legality of these programs and how the pharmacy may/should treat copay cards and/or coupons is at issue. The following Q & A is... Read More
