2022

The President and Congress extended Medicare telehealth coverage in the Consolidated Appropriations Act, which also included additional Ukrainian relief.

On Tuesday, March 15, 2022, President Biden signed the Consolidated Appropriations Act, 2022 (“2022 CAA”).  This new law includes several provisions that extend the Medicare telehealth waivers and flexibilities, implemented as a result of COVID-19 to

Highmark Health issued a Press Release on February 7, 2022 announcing that it’s Financial Investigations and Provider Review (FIPR) department generated more than $245 million in savings related to fraud waste and abuse in 2021, the majority of which was in Pennsylvania–$184 million.

Click here to see to what the Highmark FIPR Department has identified

There has been much discussion and controversy over the new CMS position on billing for split/shared services in facility settings.

As originally proposed, and starting in January 2022, if the service was shared among providers (such as physicians and physician assistants), the provider who performed the substantive portion of the visit would be the provider

There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas:

  1. The use of fraudulently obtained COVID relief funds in both healthcare and in general, but specifically as a foundation for False Claims Act enforcement.
  1. Furthermore, the reinstatement of the Yates memo of 2015 by the Deputy Attorney General Lisa Monaco’s

Under the Federal Ethics in Patient Referrals Act (more commonly known as “Stark”), if a physician[1] has a financial relationship with an entity, the physician may not refer patients to the entity for medical services payable by Medicare unless the financial relationship complies with the Stark safe harbors.  Thus, entities that lease or sublease