Tag Archives: final rule

Failing to Repay is Costly

A recent civil settlement announced by the Department of Justice reminds providers that failing to repay the government can be as costly as fraudulent billing.  Although a medical practice paid nearly $450,000 to resolve an investigation, the contested amount was only $175,000. That’s the kind of 250% penalty often associated with a false claim settlement. Similarly, this incident of failing to repay was … Continue Reading

CMS Finalizes Medicare Part C and Part D Program Changes for Contract Year 2015: Moderate Deviations from Proposed Rule

On January 8, 2014, we noted several proposed changes to the Medicare Part C and D programs as delineated in CMS’ January 8th proposed rule (hereinafter “Proposed Rule”). On Monday, May 19, 2014, CMS issued the final rule, titled Medicare Program; Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare … Continue Reading

CMS Issues Medicare and Medicaid Final Rule: Significant Changes to Conditions of Participation

On Wednesday, the Centers for Medicare and Medicaid Services (“CMS”) issued a second round of long-awaited red tape reduction initiatives aimed at ameliorating overly burdensome provider regulations.  The changes, memorialized within a Final Rule scheduled for publication on May 12, 2014 (available for review here: http://federalregister.gov/a/2014-10687) (“Unpublished Final Rule”)  include significant easing of Conditions of … Continue Reading

CMS and OIG Ring in the New Year with Final Rules on EHR Donations

On December 27, 2013, the Centers for Medicare and Medicaid Services (“CMS”) and the Office of Inspector General of the Department of Health and Human Services (“OIG”) published final rules (“Final Rules”) regarding the electronic health records (“EHR”) donations Stark Law Exception (42 C.F.R. 411.357(w)) and Anti-Kickback Statute Safe Harbor (“AKS Safe Harbor”) (42 C.F.R. … Continue Reading

Two Squire Sanders Attorneys Offer Modern Healthcare Readers Insight on the Antitrust and Fraud and Abuse Implications of the New ACO Final Rule

Squire Sanders attorneys, Chris Gordon, a Principal in the Washington, D.C. office, and Rob Nauman, a Senior Associate in the Columbus, Ohio office, were recently interviewed by Modern Healthcare for their take on the relaxation of the interim final rule on waivers of fraud and abuse laws and the antitrust policy statement on ACOs.  Their … Continue Reading

Webinar: Implications of the New ACO Regulations Announced for November 3

On Thursday, November 3rd, please join Squire, Sanders & Dempsey and Strategic Health Care for a complimentary webinar overview of the final rule recently released by the Centers for Medicare & Medicaid Services (CMS) and the opportunities it presents for Accountable Care Organizations (ACOs). As reported by the Accountable Care Forum, CMS made significant changes in … Continue Reading

CMS Releases MSSP/ACO Final Rule

On October 20, 2011, the Centers for Medicare and Medicaid Services (“CMS”) released the nearly 700-page, final rule for payments to health care providers and suppliers participating in accountable care organizations (“ACOs”) under the Medicare Shared Savings Program (“MSSP”).  In response to approximately 1,320 public comments to the proposed rule, the final rule makes a number … Continue Reading
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