By Rose Willis Accountable Care Organizations (ACOs) are organizations that have accepted responsibility for the overall quality, cost and care of a defined group of beneficiaries in compliance with the rules established by the federal government. Because ACOs are the product of a concept established by the federal government, some might overlook the application of …
Hello Insurers – Court says CGL may Cover Privacy Breaches Occurring Prior to 2014
By Wendy Hulton & Kim Ruppel In April 2013, Glens Falls Hospital admitted that the medical records for more than 2,300 of its patients were stored for several months on an unprotected computer server. The hospital’s outside records contractor, Portal Healthcare Solutions LLC (“Portal”), confirmed that it stored thousands of notes from doctors on the …
Canada-US Health IT Innovation Summit: Detroit
Join TechTown, University of Windsor, Canadian Technology Accelerator, Consulate General of Canada in Detroit, and We-Tech Alliance for the first ever Canada-US Health IT Innovation Summit in Detroit on Thursday, April 28, 2016 at TechTown. This event is a unique opportunity to connect American and Canadian companies in exploring new areas and avenues for innovation …
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Healthcare Industry Sees Increase in Malware Attacks
By Craig Phillips In the last couple of weeks, numerous large health organizations, including hospitals, have been the target of malware attacks. Last night, MedStar, which operates ten hospitals in Washington, D.C. and Maryland was hit with malware and had to take all of their computer systems, including every station in every hospital offline. MedStar, …
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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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HIPAA Privacy Rule Amendment will Permit Very Limited Reporting of Mental Health Information to the NICS
By Rose Willis An amendment to HIPAA’s privacy rules will allow a limited subset of covered entities (such as, potentially, state agencies) to disclose information to the National Instant Criminal Background Check System (NICS). The amendment takes effect February 5, 2016, and will be most relevant in those states that do not already require reporting …
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 …