You might have not noticed in the last blog post that there is a provision in the Pennsylvania Notice regarding electronic health records. The Notice does not establish a fee for electronic health records. Rather it states that the cost for production of health records in an electronic format shall not exceed the cost of
2016 Pennsylvania Medical Record Fees
By Michael Cassidy on
Posted in Uncategorized
Effective January 1, 2016, the following fees may be charged by a health care facility or health care provider in response to a request for production of medical charts or records:
| Not to Exceed | |
| Amount charged per page for pages 1-20 | $1.46 |
| Amount charged per page for pages 21-60 | $1.08 |
| Amount charged per page for |
…
Summary of UPMC/Highmark Resolved Issues
By Michael Cassidy on
Posted in Uncategorized
The following issues have been resolved over the last month, at least through June 30, 2019, which is the expiration date of the Consent Decrees entered into with the approval of the Commonwealth Court by the parties in June of 2014.
Continuity of Care. An arbitration award, a copy of which is attached, provides as…
UPMC/Highmark Continuity of Care Settlement
By Michael Cassidy on
Posted in Compliance, Legal News
PBGH just recently sent out a client alert regarding UPMC/Highmark Continuity of Care Settlement as follows: UPMC and Highmark have announced a settlement agreement that addresses the Consent Decrees’ Continuity of Care provision. This settlement will govern continuity of care beginning January 1, 2016 until the end of the Consent Decrees on June 30, 2019.…
SGR Fix Already Revised and Hospital Outpatient Department $$ Reduced
By Michael Cassidy on
Posted in Medicare & Reimbursement
The ink was barely dry on the Medicare Physician Sustainable Growth Rate (SGR) fix, and it has already been changed.
One component of the SGR fix, which was just passed in April of this year, was freezing Medicare physician payments from 2019 through 2025, and then allowing a .75% increase for physicians participating in alternative…
OIG Posts Advisory Opinion on Free Transportation Program
By Paul Welk on
Posted in Compliance, Fraud - Stark
On October 21, 2015 the Department of Health and Human Services Office of Inspector General posted Advisory Opinion No. 15-13. This Opinion relates to a request for Advisory Opinion about a plan to offer free van shuttle services to certain medical facilities in an integrated health system. The Office of Inspector General (the “OIG”) …
OCR Announces HIPAA Security Settlement with Cancer Care Group, P.C.
By Michael Cassidy on
Posted in Compliance
In September, 2015, OCR and HHS issued a press release announcing a Resolution Agreement with the Cancer Care Group, P.C., which included entry into the agreement, the adoption of a robust compliance plan, and the payment of a $750,000 penalty. The settlement arose out of an incident involving the theft of an employee laptop containing…
Office of Inspector General Issues Policy Reminder on Information Blocking and the Federal Anti-Kickback Staute
By Kristin A. Biedinger on
Posted in Uncategorized
The federal anti-kickback statute (42 USC § 1320a-7b(b), the “Statute”) prohibits individuals and entities from receiving or soliciting any remuneration for the referral of services reimbursable under any federal health care program. The Statute defines remuneration broadly to include kickbacks and rebates but also to include the purchasing or leasing of any products reimbursable under…
IRS Levy Against Medicare Payments Increases to 100% Effective October 16, 2015
By Michael Cassidy on
Posted in Medicare & Reimbursement
The Internal Revenue Code was amended in April 2015 as part of the Medicare Access and CHIP Reauthorization Act of 2015 to increase allowable IRS levies against federal payments, such as Medicare receivables, from 30% to 100% effective October 16, 2015.
CMS has issued MLM Matters – MLM number MM9285, to explain these changes.
Department of Justice Issues Guidance on Corporate Investigations and Executive Accountability
By Michael Cassidy on
Posted in Compliance
On September 9, 2015, Sally Quillar Yates, Deputy Attorney General of the Department of Justice (DOJ) issued a memo entitled “Individual Accountability for Corporate Wrongdoing” to address the issue of incentivizing executives, as individuals, to follow appropriate compliance protocols by emphasizing potential individual liability.
The memo stresses the importance and the difficulty of…