Once enrolled in the Medicare Program, physicians, other non-physician individual practitioners and physicians group practices are required to notify CMS of changes in their practice structures. These requirements are sometimes referred to as change in ownership (CHOW) rules. Physicians and other individuals are required to report the following on form CMS-855-I:
1. Change of business
In an MLN Matters announcement, a copy of which is attached at the Link below, CMS has added False Claims Act implications to reporting purchased technical components of diagnostic services. While admittedly any intentional misreporting of the purchased services would be subject to False Claims Act implications, CMS has taken the uncertainly out of this matter
The PROMETHEUS Payment(R) Model is a new program which is designed to pay providers fairly, improve quality, enhance transparency and still be more efficient than what we have today. At www.prometheuspayment.org, you will find much information about this not-for-profit, tax exempt program which has received more than $6 million from the Robert Wood Johnson
In Nasim v. Los Robles Regional Medical Center (2008 Cal. App. LEXIS 1251), a California Appellate State Court held that adoption of credentialing criteria which would retroactively deny a physician certain clinical privileges was illegal under California law.
Los Robles Regional Medical Center adopted standards requiring board certification, and those standards required that subspecialty board
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The board of the Texas Medical Liability Trust recently approved an average rate reduction of 4.7
The Department of Health and Human Services and Centers for Medicare and Medicaid Services (CMS) published final Stark IV regulations in the Federal Register on August 19, 2008. The web link is ttp://edocket.access.gpo.gov/2008/E8-17914.htm. The final regulations cover issues in addition to physician self-referral. Three issues of particular interest are the per-click compensation arrangements, the Stand-in-shoes regulations,
Check David Harlow’s HealthBlawg ( http://healthblawg.typepad.com/) for a discussion of OIG Advisory Opinion 08-10, finding that a block leasing aggreement would be a prohibited joint venture.
On August 22, 2008 the Department of Health and Human Services published a Proposed Rule that would modify two of the medical data code set standards adopted in the Transactions and Code Sets final rule. The Proposed Rule would modify the standard code sets for coding diagnoses and inpatient hospital procedures by concurrently adopting
Physicians initiating peer review litigation should be careful of two issues involving attorney’s fees. First, Section 42 USC 11113 of the Health Care Quality Improvement Act provides that hospitals may recover attorney’s fees from physicians who file frivolous or bad faith claims.
Second, sometimes the application for medical staff privileges contains clauses providing the immunity
1. Medicare Physician Fee Schedule. The sustainable growth rate (SGR) automatic physician compensation reduction of -10.6% was retroactively replaced with a .5% increase, essentially maintaining the .5% conversion factor increase implemented for January-June 2008.
2. Incentive Payments. Extends through 2010 incentive payments for implementation of electronic prescription systems (EPS).
3. Medicare Advantage Plan.