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Showing 48 posts by Julie LaVille Hamlet.

Can a Non-Physician Own and Operate a Medical Facility in Michigan?

An interesting case is winding its way through the Michigan Court of Appeals that involves the question of whether a layperson, as opposed to a licensed physician, can own a for-profit business that provides medical services. Read More ›

Categories: Compliance, Licensing, Providers

OIG Report Could Trigger Increased CMS Oversight of Skilled Nursing Facilities

The U.S. Department of Health & Human Services ("HHS") Office of Inspector General ("OIG") recently issued a preliminary report regarding quality of care concerns at skilled nursing facilities ("SNFs"). The report was issued in connection with the OIG's ongoing review of potential abuse and neglect of Medicare beneficiaries in SNFs. Read More ›

Categories: Long Term Care, Medicare/Medicaid

OIG Recommends Audits of Meaningful Use Incentive Payments

In order to encourage health providers to use electronic medical records (“EHRs”) in lieu of paper records, Congress passed the Medicare and Medicaid Health Information Technology for Economic and Clinical Health Act (“HITECH Act”) in 2009. Read More ›

Categories: HITECH Act, Medicare/Medicaid

CMS Extends Home Health Agency Enrollment Moratorium for Six Months

The Centers for Medicare & Medicaid Services ("CMS") recently extended the temporary moratorium on the Medicare enrollment of new home health agencies ("HHAs"), subunits, and branch locations in Michigan. Read More ›

Categories: Medicare/Medicaid, Providers

CMS Delays Enforcement of Nursing Home Mega Rule

Mega Rule Enforcement DelayedThe Centers for Medicare & Medicaid Services ("CMS") recently announced that they will delay enforcement penalties related to Phase 2 of their revised nursing home Requirements for Participation (commonly referred to in the industry as the "Mega Rule"). Read More ›

Categories: Compliance, Long Term Care, Medicare/Medicaid, News & Events, Providers

Michigan Health Care Providers May Now Prescribe Controlled Substances via Telemedicine

Keyboard StethoscopeGovernor Snyder recently signed into law Public Act 22 (Senate Bill 213), which revises the 2016 telehealth bill to clarify that health professionals in Michigan may prescribe controlled substances without an in-person examination. Michigan now joins a growing number of states that allow health professionals to prescribe controlled substances via telemedicine. Read More ›

Categories: Physicians, Technology

CMS Releases 2018 Inpatient PPS Proposed Rule

Medicare and Medicaid ServicesOn April 14, 2017, the Centers for Medicare & Medicaid Services issued its 2018 Medicare Inpatient Prospective Payment System proposed rule (the “Proposed Rule”). The Proposed Rule was published in the Federal Register on April 28, 2017, and comments will be accepted through June 13, 2017.

The Proposed Rule suggests a number of changes that would affect hospital rates, inpatient quality reporting and readmissions reduction programs. Some of the most significant changes are highlighted below. Read More ›

Categories: Compliance, Medicare/Medicaid, Providers

CMS Releases Final Rule Revising Conditions of Participation for Home Health Agencies

health care written informationOn January 9, 2017, the Centers for Medicare & Medicaid Services (“CMS”) issued final rules that establish minimum standards for home health agencies (the “Rules”). According to CMS, the Rules are intended to improve the quality of health care services for Medicare and Medicaid patients and strengthen patients’ rights.

The Rules, which were published in the Federal Register on January 13, 2017, come more than two years after a draft proposal was introduced in October 2014. The Rules are mostly adopted as proposed, with a few clarifying changes. The Rules will become effective on July 13, 2017. This means agencies have less than six months to make changes necessary to comply with the revisions. Read More ›

Categories: Medicare/Medicaid, News & Events, Providers

HHS OIG Report Identifies Non-Compliance in Hospice Documentation

MedicareHospice care is intended to help terminally ill beneficiaries continue living with minimal disruptions and to provide support for a beneficiary’s family and caregivers. In a recent report, the Department of Health and Human Services Office of Inspector General (OIG) found that hospices are not always meeting two key coverage requirements for the Medicare hospice benefit: (1) that beneficiaries sign an election statement and (2) that a physician certifies that the beneficiary is terminally ill. The purpose of these requirements is, among other things, to properly inform beneficiaries of the implications of hospice care and to prevent Medicare fraud. Read More ›

Categories: Long Term Care, Medicare/Medicaid

CMS Announces New Conditions of Participation for Long-Term Care Facilities

Recently, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (“Final Rule”) updating the Medicare Conditions of Participation (“CoPs”) for long-term care (“LTC”) facilities. It is the first time in over 15 years that substantial LTC CoP revisions have been released.

LTC facilities affected by the Final Rule include skilled nursing facilities for Medicare and nursing facilities for Medicaid, or those facilities that are duly certified. The Final Rule took effect on November 28, 2016, however CMS has planned for a phased implementation. LTC providers must complete the three implementation phases by November 28 in the years 2016, 2017 and 2018, respectively. CMS has estimated that the costs of compliance will be $62,900 in the first phase of implementation, and $55,000 per year for phases two and three. Read More ›

Categories: Compliance, Long Term Care, Medicare/Medicaid, News & Events, Pharmacy, Providers