The Office of Inspector General (OIG) at the Department of Health & Human Services (HHS) just published a new report on OIG’s review of Medicare payments for telehealth services. The objective of the OIG review was to determine whether or not CMS paid practitioners for telehealth services that met Medicare requirements. The report concluded that, of the sampled claims…… Continue reading this entry
On April 2, 2018, CMS released the Contract Year 2019 Final Rules for Medicare Advantage (MA) and Part D (the MA Final Rule), incorporating changes that support CMS’ stated commitment to supporting flexibility and efficiency throughout the MA and Part D Programs. The MA Final Rule incorporates broad changes to several aspects of the MA…… Continue reading this entry
On March 30, 2018, Massachusetts Governor Charlie Baker signed into law a bill intended to provide individuals with more privacy protection from their health insurance companies. The “Protecting Access to Confidential Health Care” Act (PATCH Act) gives patients the right to control who receives a summary of payment form after care is provided, helping patients…… Continue reading this entry
For the first time since the enactment of the Medicaid Drug Rebate Program (MDRP), the Centers for Medicare and Medicaid Services (CMS) revised the National Medicaid Drug Rebate Agreement (NDRA) entered into between drug manufacturers and the U.S. Department of Health and Human Services (HHS). Drug manufacturers with existing active NDRAs now have until September…… Continue reading this entry
The use of new technologies such as digital health applications, telemedicine, and information exchanges can provide game-changing benefits for providers and patients alike. However, with increased sharing comes increased risks to both the security and the privacy of patient information. Most digital health and telemedicine companies are aware of data security and breaches. However, an…… Continue reading this entry
Health care providers are under constant threat of lawsuits brought by whistleblowers under the federal civil False Claims Act, 31 U.S.C. §§ 3729, et seq. (FCA), the statute under which the government obtains most judgements against providers. These qui tam lawsuits can be costly even where they lack any merit, and counsel for providers are…… Continue reading this entry
The Delaware Board of Medicine has issued proposed regulations clarifying certain statutory provisions pertaining to telemedicine and telehealth. As we previously reported, Delaware’s Medical Practice Act imposes certain practice standards for what constitutes an appropriate patient diagnosis and treatment via telemedicine, including the allowable modalities and when an in-person examination is required. The new proposed…… Continue reading this entry
Despite some initial difficulty in gaining momentum, the use of value-based payment methodologies will likely increase across all provider niches. This change is partly a function of cost savings driven by margin compression (e.g. inpatient care) as well as by government payment models rewarding quality and efficiency, such as the Medicare Access and CHIP Reauthorization…… Continue reading this entry
California’s Medicaid agency has posted draft language of a new state plan amendment (SPA) that would make major changes to federally qualified health center (FQHC) and Rural Health Clinic (RHC) reimbursement. Public comments may be made on the proposal until 5 PM on March 23, 2018. Following review of public comments, the California Department of…… Continue reading this entry
For over a decade, Medicare has required providers to append special modifiers to their CPT and HCPCS codes when billing for telehealth services. The two primary modifiers for telehealth services were GT (indicating the service was delivered via an interactive audio and video telecommunications system) and GQ (indicating the service was delivered via an asynchronous…… Continue reading this entry