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HTMLNew Notices of Proposed Rulemaking Address Electronic Health Records
Bruce D. Armon, Evan J. Foster; Saul Ewing LLP;
Legal Alert/Article
April 15, 2013, previously published on April 2013
The Centers for Medicare and Medicaid and the Office of Inspector General have published two (2) Notices of Proposed Rulemaking extending the sunset period for permitted donations of electronic health records under the Stark Law and Anti-Kickback Statute. Comments from all interested parties are...

 

HTMLHighlighting Transparency Through The Federal Sunshine Act Regulations
Bruce D. Armon; Saul Ewing LLP;
Legal Alert/Article
April 11, 2013, previously published on April 2013
The final regulations implementing the Physician Payments Sunshine Act take effect April 9, 2013. Pharmaceutical manufacturers, group purchasing organizations, academic medical centers and physicians need to be ready to ensure compliance with the Act and the final regulations.

 

HTMLOIG Places Fraud and Abuse Spotlight on Physician-Owned Entities
Bruce D. Armon; Saul Ewing LLP;
Legal Alert/Article
March 28, 2013, previously published on March 2013
Physician-owned distributorships continue to attract federal scrutiny. A new OIG Alert highlights health care transactions that make these distributorships vulnerable to enforcement activity.

 

HTMLOIG Provides Direction and CMS Seeks Direction Relating to Electronic Activities in the Health Care Delivery System
Bruce D. Armon, Evan J. Foster; Saul Ewing LLP;
Legal Alert/Article
January 8, 2013, previously published on January 2013
The OIG recently posted an Advisory Opinion which concluded that a hospital's proposal to provide free access to an electronic interface between the hospital and area physicians for laboratory and diagnostic services was not "remuneration" under the federal Anti-Kickback Statute. In...

 

HTMLHHS OIG Agrees To Not Challenge Certain Per Diem Coverage Charge Payments to Specialist Providers Providing Services to Non-Profit Hospital Emergency Departments
Bruce D. Armon, John B. Reiss; Saul Ewing LLP;
Legal Alert/Article
December 4, 2012, previously published on November 2012
On October 30, 2012, the Office of Inspector General, Department of Health and Human Services ("OIG") posted an Advisory Opinion stating it would not challenge an arrangement in which a non-profit hospital pays per diem coverage charges to certain specialists providing services to its...

 

HTMLOIG Releases 2013 Work Plan Highlighting Upcoming Enforcement Activity
Bruce D. Armon, John B. Reiss; Saul Ewing LLP;
Legal Alert/Article
October 25, 2012, previously published on October 2012
The U.S. Department of Health & Human Services Office of Inspector General has released its Fiscal Year 2013 Work Plan. This important document provides a roadmap of potential enforcement activity by the OIG and is a friendly reminder of the subject areas that will face scrutiny during the...

 

HTMLHow Physician Practices and Physicians Can Take Advantage of the Supreme Court's Aca Ruling
Bruce D. Armon, Andrew J. Siegel; Saul Ewing LLP;
Legal Alert/Article
September 18, 2012, previously published on September 2012
The June 28th Supreme Court ruling to uphold the Patient Protection and Affordable Care Act ("ACA") removed some of the uncertainty surrounding the immediate short-term prospects for health care reform. Now that the debate over the ACA is over, it is time for physician practices and...

 

HTMLCMS Announces New Round of Advance Payment Model ACO Applications
Bruce D. Armon, Andrew J. Siegel; Saul Ewing LLP;
Legal Alert/Article
July 5, 2012, previously published on July 2012
The Centers for Medicare & Medicaid Services has designed an Advance Payment Model for participants in the Medicare Shared Savings Program, giving them advance payments that will be repaid from the future shared savings they earn.

 

HTMLNew ONC Guide Helps Physicians Understand HIT Privacy, Security Issues
Bruce D. Armon, Andrew J. Siegel; Saul Ewing LLP;
Legal Alert/Article
May 29, 2012, previously published on May 2012
The federal government has released a comprehensive guide to help healthcare professionals understand the role of privacy and security when implementing health information technology.

 

HTMLCMS Final Rule Requires NPI Submission for Medicare and Medicaid Provider Enrollments and Orders
Bruce D. Armon, Andrew J. Siegel; Saul Ewing LLP;
Legal Alert/Article
May 4, 2012, previously published on May 2012
Despite the recent debate in the U.S. Supreme Court regarding the constitutionality of the health care reform act, CMS published a final rule related to several provisions from the Affordable Care Act (the "Act").

 


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