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Provider ALERT: 2020 Medicare Physician Fee Schedule Includes Expansion of Revocation Authority

Upon the annual announcement of the Medicare Physician Fee Schedule, providers are typically focused on the new payment rates and policies, but the 2020 version includes an expansion of revocation authority about which all enrolled providers must be aware. The Centers for Medicare & Medicaid Services (CMS) has always retained the discretion to deny or revoke a provider's enrollment status and corresponding billing privileges for violations of CMS rules, but...

New CMS Rule: Program Integrity Enhancements to the Provider Enrollment Process

The Centers for Medicare & Medicaid Services (CMS) recently announced a final rule entitled "Program Integrity Enhancements to the Provider Enrollment Process." The new rule, which will go into effect on November 4, 2019, requires Medicare, Medicaid, and Children's Health Insurance Program (CHIP) providers and suppliers to disclose any current or previous direct or indirect "affiliations" (as specifically defined by CMS) with another provider or supplier that: has uncollected debt...

Recent DOJ Complaint Targets Hospital’s Compensation Arrangements with Physicians

On March 25, 2019, the U.S. Department of Justice (DOJ) filed a 49-page, multi-count complaint in Pennsylvania federal court against Wheeling Hospital in West Virginia, citing the hospital’s payments to physicians as violating the Anti-Kickback Statute, Stark Law and False Claims Act (FCA). The alleged fraud scheme includes, but is not limited to, incentive compensation paid to physicians employed by the hospital and suspect equipment rental arrangements with a radiology...

Provider ALERT: Open Payments Review Period Begins April 1st

The Open Payments program collects and publishes data regarding financial relationships between the healthcare industry, including applicable drug and device manufacturers and GPOs, and healthcare providers ("Covered Recipients") on a publicly accessible website that enables consumers of health care to search, download, and evaluate the reported data. The law that gave rise to the program is commonly referred to as the Physician Payments Sunshine Act, or simply the "Sunshine Act."  ...

Owners of Several Dental Clinics Face Prison Terms

The owners of several Missouri dental clinics were recently convicted for defrauding the government by submitting false claims to Medicaid and failing to pay payroll taxes. The owners, who are a married couple, operated three All About Smiles LLC dental clinics and a separate management company. In a collaborative effort, the Department of Health and Human Services – Office of Inspector General, the Missouri Attorney General’s Office Medicaid Fraud Control...