Articles and Blogs

Background On January 18, 2017, the United States Department of Health and Human Services (“HHS”) Substance Abuse and Mental Health Services Administration (“SAMHSA”) issued final regulations (the “Final Rule“) intended to update and modernize the Confidentiality of Alcohol and Drug Abuse Patient Records regulations at Title 42 of the Code of Federal Regulations, Part 2…Read More

Review of the New Home Health Conditions of Participation – Release of Patient Identifiable OASIS information, Reporting OASIS Information and Comprehensive Assessment of Patients; and Care Planning, Coordination of Services and Quality of Care. This is the second article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the…Read More

ACA Replacement Picture Remains Unclear Details on how the incoming Trump administration will replace the Affordable Care Act (“ACA”) remain unclear as President Donald Trump was sworn in on January 20 as the 45th president. Trump indicated in a recent press conference that his replacement plan will be unveiled once Rep. Tom Price (R-GA) is…Read More

Background On January 18, 2017, the Department of Health and Human Services (“HHS”), through the Office of Human Research and Protection (“OHRP”), issued final regulations (the “Final Rule“) implementing significant changes to the Federal Policy for the Protection of Human Subjects (the “Common Rule”). The Final Rule follows HHS’s September 2015 notice of proposed rulemaking…Read More

On January 12, 2017, the Department of Health and Human Services Office of Inspector General (“OIG”) published the “Health Care Programs: Fraud and Abuse; Revisions to the Office of Inspector General’s Exclusion Authorities” Final Rule (“Final Rule”) revising and expanding its authority to exclude individuals and entities from participation in federal health care programs. The…Read More

On December 20, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a Final Rule that included several changes to the recently implemented Comprehensive Care for Joint Replacement (“CJR”) program. The CJR Model is a retrospective bundled payment program limited to lower extremity joint replacement (“LEJR”) procedures and is designed to encourage hospitals to…Read More

Background On December 20, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a final rule (the “Final Rule”)1 creating three new episode payment models (“EPMs”) covering services provided to Medicare beneficiaries admitted to certain Inpatient Prospective Payment System (“IPPS”) hospitals for heart attacks, coronary bypass surgery or surgical treatment of hip or femur…Read More

Review of the New Quality Assessment and Performance Improvement Condition This is the first article in a series discussing CMS’s pre-publication copy of the Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing, with only a few changes, the significant changes they proposed to make…Read More

This month, the Centers for Medicare & Medicaid Services opened the registration and attestation system for the Medicare Meaningful Use Incentive Payment Program for 2016.  Eligible providers participating in the Medicare Meaningful Use Incentive Payment Program must attest to the 2016 Medicare Meaningful Use Program requirements by February 28, 2017 at 11:59 PM EST in order to…Read More

On January 3, 2017, Governor Rick Snyder signed House Bill 4598 (“HB 4598”) into law. HB 4598 adds Part 171 (Midwifery) to the Public Health Code and provides new licensure requirements for the practice of midwifery in Michigan. Effective immediately, the bill establishes midwife licensure and scope of practice requirements, including: Prohibiting an individual from…Read More