On December 12, 2018, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR), requested public comments on potential changes to the Health Insurance Portability and Accountability Act’s regulations (HIPAA) that are perceived to be burdensome by the industry. The Request for Information (RFI) focuses on HIPAA requirements that limit or…… Continue reading this entry
The medical credentialing process, whether for a hospital, a hospital system or a health plan, has emerged as a potential early target for the application of blockchain technology and administration.1 It is a process that allows a secure database to be established over time and on a cumulative basis. Medical credentialing involves verifying whether a…… Continue reading this entry
On November 30, 2018, the Centers for Medicare & Medicaid Services (CMS) published 83 Fed. Reg. 62152, which proposes changes to Medicare Part D (prescription drug benefit) and drug plans offered by Medicare Advantage (managed care) in an effort to reduce out-of-pocket costs for beneficiaries. The proposed rule is part of the Trump Administration’s four…… Continue reading this entry
Most busy scientific research laboratories have a spectrum of projects underway at any given time. Some projects are producing exciting results, and others seem to be heading nowhere. Why not shift personnel from the losers to the winners? Here’s one big reason: The government is watching. And unless you’re careful, simply moving a couple of…… Continue reading this entry
This year marks the 15th anniversary of the completion of the Human Genome Project. In the decade and a half that has passed since, the genomic revolution has spurred an immeasurable level of excitement and support surrounding the promise of personalized medicine, setting high expectations for a new era of health care and rapidly transforming…… Continue reading this entry
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