Articles and Blogs

Centers for Medicare and Medicaid Services

CMS Letter to Clinicians – E/M Documentation Update

[11/09/18]

Posted on November 9, 2018 in Health Law News

Published by: Hall Render

On November 8, 2018, CMS released a letter to clinicians regarding E/M documentation and coding reform. This follows the CY 2019 Medicare Physician Fee Schedule Final Rule intentions to reduce burden on clinicians in furtherance of the agency’s “Patients Over Paperwork” initiative. Effective January 1, 2019, CMS will: Simplify the documentation of history and exam... READ MORE

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CMS Proposes to Simplify Coding and Documentation Requirements for E/M Services but with a Catch

[09/28/18]

Posted on September 28, 2018 in Health Law News

Published by: Hall Render

On July 12, 2018, the Centers for Medicare & Medicaid Services (“CMS”) released its proposed rule for the Calendar Year (“CY”) 2019 Medicare Physician Fee Schedule (“Proposed Rule”). Among many other changes, CMS proposed numerous modifications to the required documentation for evaluation and management (“E/M”) visits in order to alleviate the administrative burden on practitioners and... READ MORE

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CMS Allows Medicare Advantage Plans to Implement Step Therapy for Part B Drugs – Will It Really Lower Drug Costs or Simply Increase Administrative Burdens?

[09/19/18]

Posted on September 19, 2018 in Health Law News

Published by: Hall Render

On August 7, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum (“Memorandum”) announcing a policy change to allow Medicare Advantage (“MA”) plans to implement step therapy programs for physician-administered and other Part B drugs. Step therapy is a type of prior authorization for drugs in which a health plan requires... READ MORE

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CMS Proposes Several Changes for Off-Campus Provider-Based Clinics

[08/03/18]

Posted on August 3, 2018 in Health Law News

Published by: Hall Render

On July 12, 2018, the Centers for Medicare & Medicaid Services (“CMS”) released its proposed rule for the Calendar Year (“CY”) 2019 Medicare Physician Fee Schedule (“MPFS Proposed Rule”). Among many other changes, CMS proposed to maintain payments for certain non-excepted (non-grandfathered) off-campus provider-based hospital departments (“PBDs”) at 40 percent of the Outpatient Prospective Payment System... READ MORE

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A Twenty Year Statute of Limitations?

[03/15/12]

Posted on March 15, 2012 in False Claims Act Defense

Written by: David B. Honig

Last month the Centers for Medicare & Medicaid Services (CMS) published proposed rules for reporting of overpayments. These proposed rules, if adopted and strictly interpreted, could effectively create a twenty-year statute of limitations under the False Claims Act. READ MORE

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