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HIPAA Requirements and the Benefits to Being Proactive

It is likely you have seen headlines and possibly read a few articles about the risks and liabilities that physicians are exposed to if they don't adequately comply with the myriad of requirements under the HIPAA Privacy and Security Rules: "Don't Neglect Business Associate Agreements” reads one headline, "Closing HIPAA Compliance Gaps: Getting your Policies in Order," or "The Top Ten HIPAA Violations and How to Prevent Them" read a...

The Status of Per-Click Restrictions Under the Stark Law

On June 12, 2015, the U.S. Court of Appeals for the District of Columbia Circuit issued a decision in the Council for Urological Interests v. Burwell case that could have a significant impact on the regulatory prohibition on per-click equipment leases under the Federal Stark Law. The regulation in question prohibits equipment leases that charge a hospital for each use of the equipment, or a “per-click” use, and the regulation instead...

Chronic Care Management: Developments and New Requirements for Hospitals and Physicians

Following the publication of the 2015 Medicare Physician Fee Schedule Final Rule in which the Centers for Medicare and Medicaid Services (CMS) began allowing for reimbursement for provision of chronic care management (CCM) services, there have been a number of important developments around CCM which impact both hospitals and physicians. In mid-February of this year, CMS held a call as part of the Medicare Learning Network (MLN), and the call...

Medical Director Arrangements Under Increased Scrutiny

While not an entirely new topic, there has been a significant increase in the amount of attention focused on the subject of medical director compensation arrangements. On June 9th, the OIG issued a Fraud Alert on physician compensation arrangements, in which it emphasized the importance of “ensuring that those arrangements reflect the fair market value for bona fide services the physicians actually provide.” OIG issued the alert after reaching settlements...