Dickinson Wright PLLC is pleased to announce that the firm’s healthcare practice group is ranked 35 on Modern Healthcare’s Largest Healthcare Law Firms list. Dickinson Wright is the only Michigan-based law firm represented on the list. The list appears in the June 27th issue of Modern Healthcare. Dickinson Wright’s healthcare practice group includes more than …
Analysis of New Timeshare Arrangement Exception to the Stark Law – Part 2
By Marki Stewart In a previous post, we analyzed the new Timeshare Arrangement exception to the Stark law that CMS proposed and went into effect on January 1, 2016. Here we give an example of how the new timeshare arrangement exception works as it relates to rental of office space. Client’s Block Lease A client …
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Analysis of New Timeshare Arrangement Exception to the Stark Law – Part 1
By Marki Stewart On July 15, 2015, the Centers for Medicare & Medicaid Services (CMS) proposed a series of rules that would create new exceptions to the Stark law, in addition to clarifying other provisions of the Stark law. One of the newly created exceptions is for “Timeshare Arrangements.” (effective January 1, 2016). This exception …
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Physician Compliance Programs: What you need to know about the Final 60-Day Rule
By Rose Willis The 60-Day Rule was enacted as part of the Affordable Care Act on March 23, 2010 and generally requires a person who has received an overpayment to report and return the overpayment by the later of (i) the date which is 60 days after the date on which the overpayment was identified; …
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3 Things to Consider When Dealing with Bundled Payments to Providers
By Ralph Levy The Centers for Medicare & Medicaid Services (CMS) has traditionally paid health care providers separately for each of the individual services they furnish to beneficiaries for a single illness or course of treatment. This approach to payments rewarded a quantity versus quality of care and could result in fragmented care with minimal …
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New Stark Law Exception Allows Hospitals, FQHCs, and RHCs to Assist Physicians with Engaging Non-Physician Practitioners
By Rose Willis The Centers for Medicare & Medicaid Services (CMS) recently released a new exception to the Physician Self-Referral Law (the “Stark Law”) intended to expand access to primary care and mental health services (the “NPP Recruitment Exception”). This exception would permit hospitals, federally qualified health centers (FQHCs) and rural health clinics (RHCs) to …
New CMS Proposed Rule Provides Who/What/When for Clinical Laboratory Reporting Requirements Starting January 1, 2016
By Rose Willis Clinical laboratories will see significant changes to their Medicare payments for clinical diagnostic laboratory tests (CDLTs) starting January 1, 2017, but the basis for new payment rates will come from “applicable data” reported by “applicable clinical laboratories” starting January 1, 2016. Failure to report data will subject the applicable laboratory to Civil …
Care Recipients’ Limited Right to Discriminate Based on Protected Characteristics of Care Provider
By David J. Houston Healthcare provider institutions including hospitals, clinics, medical practices, nursing homes and home health care providers (here, “Institutions”) are occasionally called upon to balance the preferences of Consumers against the interests or possible rights of their employee Care Providers. This may occur when Consumer complaints target assigned direct Care Providers – nurses, …
Tennessee Attorney General States that Physical Therapists Cannot Perform Trigger-Point Dry Needling
By Keith C. Dennen In an opinion released on June 19, 2014, the Office of the Tennessee Attorney General stated that Physical Therapists cannot lawfully perform Intramuscular Manual Therapy or Trigger-Point Dry Needling. Dry Needling therapy involves application of a fine, filiform needles to the neuromusculoskeletal system to restore movement, reduce pain, and address other …
Peer Review is not always Privileged
By Keith C. Dennen Hospitals, ambulatory surgery centers and independent diagnostic centers cannot exist without physicians and other medical providers. In order to practice at those facilities, the medical professional often is required to be “admitted” to the medical staff of the facility. Although admission to the medical staff provides privileges, it often requires that …