Practical considerations to protect against being ‘out of network’
The disengagement of Highmark and UPMC is looming on the horizon; most of the hospital participation agreements between these two competing healthcare systems end on December 31, 2014. There are some hospital agreements that continue, such as those at Children’s and Magee, but the focus of…
OCR PREPARING FOR NEXT ROUND OF HIPAA AUDITS
In a February 24, 2014 notice published in the Federal Register, the Department of Health and Human Services announced a pre-audit survey of HIPAA covered entities and business associates. The information collected will involve a survey of up to 1,200 covered…
Despite the many cases acknowledging the right of hospitals to enter into exclusive contracts, there is always the issue of what happens with the existing clinical privileges and medical staff memberships of the physicians who are being replaced, assuming they are not the physicians receiving the exclusive contract. Defenders of physician rights have typically argued …
Microsoft recently announced that, after April 8, 2014, it will not longer provide security updates or technical support for Windows XP. Microsoft’s statement that “businesses that are governed by regulatory obligations such as HIPAA may find that they are no longer able to satisfy compliance requirements” has spurred a certain level of panic among health…
Attorneys routinely advise clients conducting audits and investigations that the audit or investigation should be conducted by outside counsel in order to establish attorney client privilege.
One of the problems with the OIG Self Disclosure protocol is that it requires the waiver of attorney client privilege. Now a federal district court has decided that audits …
In Fahlen v. Sutter Central Valley Hospitals, the California Supreme Court found:
The…
The 2014 OIG Work Plan includes the following:
Billing and Payments. We will identify questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A (for example, stays during which benefits are exhausted or the 3-day prior-inpatient-stay requirement is not
…
The 2014 OIG Work Plan includes the following:
Policies and Practices. We will determine the impact of subordinate facilities in hospitals billing Medicare as being hospital based (provider based) and the extent to which such facilities meet CMS’s criteria. Context—Provider-based status allows a subordinate facility to bill as part of the main provider. Provider-based status
…
The 2014 OIG Work Plan includes the following:
Quality of Care and Safety. We will determine how hospitals assess medical staff candidates prior to granting initial privileges, including verification of credentials and review of the National Practitioner Databank. Context—Hospitals that participate in Medicare must have an organized medical staff that periodically appraises its members (42
…
New joint legislation to repeal Medicare’s failed SGR formula is advancing to both chambers of Congress following an agreement announced Thursday by the three committees that put forth repeal bills earlier this session.
“The AMA congratulates House and Senate negotiators for taking this critical step toward reforming the nation’s Medicare program,” AMA President Ardis Dee…
