CMS Stark Law Self Disclosure – New Form and Process for Self Disclosing Stark Law Violations

The Centers for Medicare and Medicaid Services (CMS) has issued new forms and procedures for provider self-disclosure of Stark Law violations. The new material is intended to streamline the process that permits providers to self-disclose Stark Law violations.  The process is applicable to violat...

What Does the HIPPA Phase2 Audit Program Mean for Physicians?

HIPAA Audits of Physician Practices – Phase II Audits The HHS Office for Civil Rights (“OCR”) has Officially announced The commencement of its 2016 Phase 2 HIPAA Audit . In Phase 2, OCR Will be reviewing the policies and procedures of covered entities and their business associates. This phase of ...

Health Law and Compliance Blogs

Health Law Blog  www.healthlaw-blog.com Wisconsin Health Lawyers www.wisconsinhealthlawyers.com Hospice Lawyers www.hospice-lawyer.com Compliance Lawyers www.compliance-lawyers.com Automated Incorporating Blog www.automated-incorporating.com/blog/ Physicians Health Lawyers www.physicianslawyers....

Revision to Medicare oversight or provider based status.

Hospital Provider Based Status Review OIG 2016 Work Plan Coverage   There’s a lot of activity in the area of provider based facilities and hospitals outpatient departments. Laws are changing to equalize reimbursement that is available between provider-based and physician office settings. Service...

New 2016 Work Plan Indicates Area of Compliance Focus

OIG 2016 Work Plan Highlights Areas of Fraud and Abuse Concern Each year the Office of Inspector General puts out a work plan that indicates the priorities that it will look up at during the upcoming year. The OIG is an organization that was created to protect the integrity of the HHS program ope...

Ambulatory Surgery Center Forced Exclusions – lets be honest for a minute, shall we?

Excluding Non-performing Positions from a Physician Owned Surgery Center   Many surgery centers are eventually faced with decisions about how to treat investing physicians who do not perform as many procedure procedures in the surgery center as others.  Under-performing physicians can create pol...

Medical Director Agreement Payments May Be Source of Stark Law Compliance Concerns

MEDICAL DIRECTOR PAYMENTS AS STARK LAW VIOLATIONS The relatively recent case serves as a reminder of the potential exposure to Stark Law liability arising from payments to medical directors.  Let me immediately clarify that not all payments to directors who perform legitimate services that are a...