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CMS Proposes Changes to Bundled Payment Requirements

Last month, the Centers for Medicare and Medicaid Services (CMS) announced a proposed rule which would eliminate the requirement that beginning January 1, 2018, providers would be required to participate in certain mandatory bundled payment programs. The proposed rule seeks to cancel the Episode Payment Models (EPMs) and Cardiac Rehabilitation (CR) incentive payment model, and revise certain aspects of the Comprehensive Care for Joint Replacement (CJR) model. These alternative payment...

Challenges with Physician Compensation Plans

While at first glance it may not seem concerning to compensate a physician with a package that matches the pay the physician was earning at a prior point in his or her career, it can potentially lead to serious penalties under both the False Claims Act and Stark Law if the compensation is not structured in compliance with the Stark Law. At the end of last month, the U.S. Department...

What You Need to Know About Forming a Super Group

This article was originally published in the Autumn 2016 issue of Viewpoint Magazine and is reprinted here with permission. View PDF version of this article. The increased emphasis on cost, quality and compliance in the delivery of healthcare has simultaneously promised to save our healthcare system, while adding immense complexity to the private practice of medicine. The advent of MACRA and all of the intricate payment methodologies proposed by CMS...

New Players in the Chronic Care Management Market and the Potential for Abuse

The introduction of reimbursement for Chronic Care Management (CCM) services by the Centers for Medicare and Medicaid Services presents an opportunity to better care for patients with chronic illnesses and to receive payment for the time spent caring for these patients. It also presents an opportunity for companies to assist physician practices in performing CCM services. You may have read recent articles about such a company, a publicly traded pharmaceutical...

OIG Reports on HIPAA Oversight Could Signal Changes in HIPAA Enforcement

Recent OIG reports signal an upcoming increase in OCR activity and oversight of HIPAA covered entities, even in the absence of a breach. On September 29th, the Office of Inspector General (OIG) in the U.S. Department of Health and Human Services (HHS) released two reports which reviewed the successes and shortcoming in the Office for Civil Rights' (OCR) oversight of Health Insurance Portability and Accountability Act (HIPAA) compliance for covered...