CMS just announced a clarification that remote patient monitoring under CPT code 99457 may be furnished by auxiliary personnel, “incident to” the billing practitioner’s professional services. An “incident to” service is one that is performed under the supervision of a physician (broadly defined), and billed to Medicare in the name of the physician, subject to…… Continue reading this entry
Website accessibility under the Americans with Disabilities Act of 1990 (ADA) and Rehabilitation Act of 1973 (Rehabilitation Act) is an issue of which health care providers and other health care companies should be aware. There have been lawsuits filed that include claims for website accessibility under these Acts. A number of entities, including health care…… Continue reading this entry
The Massachusetts Medicaid Program (known locally as MassHealth) issued a new All Provider Bulletin in January, setting forth new policies for certain behavioral health services delivered to MassHealth covered patients. The guidance received mixed responses from the telehealth industry. The good: MassHealth-participating Community Health Centers, Community Mental Health Centers, and Outpatient Substance Use Disorder providers…… Continue reading this entry
In response to the opioid crisis, the Drug Enforcement Administration (DEA) is cracking down on pharmacies, pharmacists, and prescribers by leveraging an old enforcement weapon: revocation of controlled substance registrations. The DEA actively revived this enforcement mechanism in February and March of 2018 when it arrested 29 people and revoked 147 controlled substance registrations throughout…… Continue reading this entry
On February 27, 2019, CMS will hold its first webinar to provide an overview on its new Emergency Triage, Treat, and Transport (ET3) Model for suppliers of emergency medicine services (EMS) and ambulance suppliers. On February 14, 2019, CMS’ Innovation Center announced ET3’s upcoming availability, which emphasizes the need for EMS suppliers to partner with…… Continue reading this entry
Co-Author: Nina Zhang, Stephenson Acquisto & Colman This article addresses the high-level challenges of tackling drug pricing policy related to prices that seniors and government programs pay, as well as the potential effects that the Trump administration’s policy efforts could have on those prices.1 Starting in January 2019, the Centers for Medicare & Medicaid Services…… Continue reading this entry
In November 2018, I had the honor and pleasure of speaking at the AHLA Fundamentals of Health Law program in Chicago. This is a conference that is designed for attorneys (and others) who are relatively new to health law. I spoke on the exciting topic of “Medicare Parts A and B.” As I prepared for…… Continue reading this entry
Virginia lawmakers have taken new steps to expand the use of remote patient monitoring among the State’s residents, with both the House and Senate unanimously passing bipartisan legislation ensuring that commercial health plans and the Virginia Medicaid program will cover remote patient monitoring services. The bill now heads to the office of Governor Ralph Northam…… Continue reading this entry
Last week, the federal HHS Office of Inspector General (OIG) gave the greenlight to allow a virtual care company and pharmaceutical manufacturer to loan patients free smartphones, so the patients (which include Medicare beneficiaries) could use the smartphones to track their drug therapy adherence via a mobile digital health app. The OIG’s recent Advisory Opinion…… Continue reading this entry
On January 9, 2019, the American Telemedicine Association (ATA) issued a policy comment letter to the U.S. Drug Enforcement Administration (DEA), advocating for provider-friendly changes to federal controlled substance prescribing rules. Note: the firm’s Telemedicine & Digital Health Industry Team participated in the ATA’s special workgroup to develop the recommendations. The letter offers recommendations for DEA’s…… Continue reading this entry