Authentication of Verbal Orders by Other Responsible Practitioner

Prompt Authentication of Verbal Orders ; Verbal Order Risks The failure of a physician to timely sign a verbal order can have reimbursement implications. In some cases, in some states, another responsible provider can sign a verbal order that is originally given by another practitioner. This opti...

Telemedicine Compliance Series – Licensing Issues in Telehealth

How Telemedicine Licensing Issues Arise – Compliance for Telehealth Programs The practice of medicine is licensed and regulated at the state level.  The jurisdiction of individual states over medical licensure is broadly recognized by the courts and the federal government, including CMS.  The f...

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...

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...

60 Day Repayment Rule False Claims Act

The 60-Day Repayment Rule and False Claims Act Providers Get Another Push Into Proactive Compliance The Patient and Program Protection Act (“PPACA”) added a number of additional tools to the government’s fraud fighting arsenal.  One of those tools is found in PPACA Section 6402 and require...

Ambulatory Surgery Center Structural and Valuation Issues

ASC Regulatory and Structural Issues   A recent “advanced session” was provided by the American Health Lawyer’s Association covering several of the central legal issues that arise with respect to ASC ownership and structure.  The general issues covered in the webinar included:   1.A...