Medicare’s 60-Day Proposed Refund Rule Imposes Significant Liability on Providers

More good news for hospitals, health care providers, and entrepreneurs interested in telehealth and Chronic Care Management (CCM).  CMS just recently introduced a new educational initiative called Connected Care: the Chronic Care Management Resource.  The initiative is designed to raise awareness of the benefits of CCM services for Medicare beneficiaries with multiple chronic conditions and … Continue reading this entry

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Background Health Plans and health care providers are getting into each other’s business.  This payor/provider convergence has taken different forms.  Health systems have ventured into the health insurance business by acquiring or starting their own health plans and by establishing joint ventures with payors, to jointly own and operate a health plan.  Health plans have … Continue reading this entry

3-HospitalComplex

Foley recently co-hosted the Florida Hospital Association’s (FHA) 2017 Health Law Summit, which brought together more than 40 in-house attorneys and compliance officers from FHA member hospitals to discuss the current state and future direction of the health care industry. Amid so much economic and political uncertainty, we are diligent about keeping our fingers on … Continue reading this entry

Capitol

The US Department of Justice (DOJ) Fraud Section has published new guidance for corporate entities on corporate compliance programs.  The guidance, titled, “Evaluation of Corporate Compliance Programs” (Compliance Program Evaluation)  provides companies – and their compliance teams – with key insights into how government regulators will assess efforts taken to develop, implement and evaluate the … Continue reading this entry

blood system

“A robust, sustainable blood system is a crucial component of every health care system.”  That is how Rand Corporation’s recently issued comprehensive report entitled “Toward a Sustainable Blood Supply in the United States” (the “Report”) begins.  Issued as a result of research sponsored by the U.S. Department of Health and Human Services (“HHS”), the Report … Continue reading this entry

Regulatory-Developments

On Jan. 12, 2017, the Office of Inspector General of the U.S. Department of Health and Human Services issued the third and final installment of its recent three-part rulemaking effort — a final rule updating its exclusion regulations, 82 Fed. Reg. 4100 (Jan. 12, 2017). This final rule follows two others that were published in December updating the OIG’s civil monetary … Continue reading this entry

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New Hampshire is starting 2017 with stepped-up efforts to manage its oft-described opioid epidemic.  Though the most recent regulations are directed at individual prescribers, and do not apply to the administration of opioids to patients in a health care setting, now is the time for New Hampshire hospitals, ambulatory surgical centers, urgent care facilities, and … Continue reading this entry