Section 6409 of the Patient Protection and Affordable Care Act (PPACA) required CMS to develop a Medicare Self-Referral Disclosure Protocol (SRDP) to facilitate the resolution of potential Stark violations. The SRDP was published on September 23, 2010 with two caveats:
1. Despite the fact that potential violations or situations might violate more than just the Stark
Contributed by Michael Cassidy & Donna Kell
mcassidy@tuckerlaw.com, djk@kellgroup.com
An overlooked byproduct of health care reform and the general economic recession is the “multiplier” effect of larger deductibles and co-pays and the reduced ability of patients to make those payments, resulting in more collection problems and the perhaps unintended creation of consumer financing issues. This
New – Medicare Self-Referral Disclosure Protocol
CMS has published the self referral disclosre protocol required by ACA. Link and announcement below. Analysis will be posted next week.
Section 6409(a) of the Affordable Care Act (ACA) ACA requires the Secretary of the Department of Health and Human Services, in cooperation with the Inspector General of
Contributed by Jo-Anne Mineweaser
jmineweaser@tuckerlaw.com, 412.594.3920
The Patient Protection and Affordable Care Act and subsequent regulations set forth new rules for group health plans regarding the processing of claims and appeals. These rules are effective for plan years beginning on or after September 23, 2010 (January 1, 2011 for calendar year plans) and apply
In OIG Advisory Opinion No. 10-14, the OIG concluded that it would not seek enforcement of the Anti-Kickback Statutes under an arrangement in which an independent sleep testing provider entered into an arrangement to provide a hospital-owned sleep testing facility with equipment and staff on a per test basis.
CMS has created a web page on EHR Incentive Programs. Click on this link or the button below to go to the CMS web page.
Contibuted by Jo-Anne Mineweaser
412.594.3920, jmineweaser@tuckerlaw.com
On September 3, 2010, the Internal Revenue Service issued Notice 2010-59 to provide guidance on the revised definition of “medical expenses” under the Patient Protection and Affordable Care Act. Beginning on January 1, 2011, expenses incurred for medicines or drugs may be paid or reimbursed by an employer-provided plan
In Vranos v. Skinner, the Massachusetts Appeals Court reaffirmed the doctrine of exhaustion of administrative remedies. The Court affirmed the dismissal of the lawsuit arising out of a summary suspension of a physician’s staff privileges. The bylaws of Franklin Medical Center contained the typical internal grievance procedures. Dr. Vranos alleged that the hospital had not complied with