The past decade has seen a tremendous amount of private equity investment in physician practice recapitalizations, primarily in hospital-based practices such as anesthesiology and radiology as well as “retail medicine practices” like dermatology and ophthalmology/optometry, to name a few. Orthopedics, on the other hand, has received less attention from investors, but we believe that trend…… Continue reading this entry
On November 2, 2018, CMS released an on-line display copy of its Outpatient Prospective Payment System (OPPS) Final Rule implementing payment changes effective January 1, 2019. The official Federal Issuance is expected on November 21, 2018. One anticipated set of changes in the Final Rule is related to off-campus outpatient hospital departments (OCODPs). Background Medicare…… Continue reading this entry
Practitioners in the Medicare or Medicaid managed care space place heavy reliance on the protection of the Anti-Kickback Statute (AKS) Safe Harbor found at 42 C.F.R. § 1001.952(t), generally known as the “EMCO [eligible managed care organization] Safe Harbor,” as they look at incentive arrangements between providers and managed care plans. Although the language of…… Continue reading this entry
In a final rule published on January 19, 2017, HHS and several federal departments and agencies made revisions to the Common Rule, the federal policy for the protection of human subjects applicable to human subject research conducted or supported by participating federal departments and agencies.[1] Compliance with the revised Common Rule is expected on January…… Continue reading this entry
Starting January 1, 2019, the Medicare program will cover certain medical services delivered via asynchronous telemedicine technologies. The Centers for Medicare and Medicaid Services (CMS) just published the final rule for the 2019 Physician Fee Schedule, introducing a new code, officially titled “Remote Evaluation of Pre-Recorded Patient Information” (HCPCS code G2010). This article provides the…… Continue reading this entry
Telemedicine providers rejoice: Medicare will cover new virtual care services starting January 1, 2019. The Centers for Medicare and Medicaid Services (CMS) just published the final rule for the 2019 Physician Fee Schedule, introducing a new code: Virtual Check-Ins, officially titled “Brief Communication Technology-Based Service” (HCPCS code G2012). This article discusses the new code and…… Continue reading this entry
Remote Patient Monitoring (RPM) is the next big thing in medical care; patients just don’t know it yet. And, it seems, neither do many physicians. On Thursday, CMS published the final rule on its new RPM codes, officially titled “Chronic Care Remote Physiologic Monitoring.” There are three new RPM codes, all of which will go live starting January 1, 2019. These codes…… Continue reading this entry
The alarming news about potential research misconduct can come in a variety of ways: a negative report in Retraction Watch, an anonymous “Clare Francis” letter, or a tip on the employee hotline. Regardless of the source, every institution must take each allegation seriously, especially if it involves research funded with federal dollars. Not only can a…… Continue reading this entry
President Trump just signed into law the “Special Registration for Telemedicine Act of 2018” (the Act), requiring the Drug Enforcement Administration (DEA) to activate a special registration allowing physicians and nurse practitioners to prescribe controlled substances via telemedicine without an in-person exam. The DEA has no more than one year to complete the task. Until…… Continue reading this entry
On November 6, 2018, when Massachusetts voters go to the polls to select a new Governor and other key elected officers, they will also consider Ballot Question 1, which will mandate rigid registered nurse staffing ratios for hospitals across the Commonwealth effective as of January 1, 2019. This proposal would make Massachusetts the second state…… Continue reading this entry