Beyond the Essential Elements of a Compliance Program

There’s no shortage of information on the internet and in training manuals on the essentials of a compliance program. From implementing written policies to developing effective lines of communication and responding promptly to detected offenses, the steps to creating a compliance program have been well-defined, but it’s no longer enough to simply have a compliance program, it must be an [...]

By |2016-12-27T11:06:18-06:00September 27, 2016|

Internal Investigations in Healthcare — Conducting an Internal Investigation (Part Two)

In the first part of this series regarding internal investigations, we discussed (1) the need to assess whether to conduct an internal investigation, and (2) if an internal investigation is appropriate, how to best prepare for the investigation. Our second part in this series covers the following: How to conduct the investigation; How to develop a corrective action plan; and [...]

By |2016-12-27T11:06:19-06:00August 25, 2016|

CMS’ Comprehensive Primary Care Plus Includes Colorado

The Centers for Medicare & Medicaid Services (CMS) announced this month that Colorado will be one of 14 regions (11 states and 3 large metropolitan areas) that will participate in a CMS initiative called Comprehensive Primary Care Plus, or CPC+. CMS originally announced CPC+ in April, describing it as the “future of primary care.” Under CPC+, CMS is offering primary [...]

By |2016-12-27T11:06:19-06:00August 16, 2016|

The Medicare Outpatient Observation Notice Goes into Effect

Beginning on Aug. 6, hospitals must notify Medicare patients in writing that they are being admitted as an outpatient, observational basis within 36 hours of beginning observational services. The Medicare Outpatient Observation Notice (more commonly known as “MOON”) is part of the NOTICE Act, which was signed by President Obama in August of 2015. The NOTICE Act was designed to [...]

By |2016-12-27T11:06:19-06:00August 15, 2016|

New Report Finds Signs of Fraud in Some Home Health Agencies

The federal Department of Health and Human Services recently issued an alert warning that it was stepping up enforcement efforts against fraud and abuse by home health agencies, a response to a new report which finds many such agencies are displaying the warning signs of fraud. The HHS’ Office of the Inspector General said in its report that approximately five-percent [...]

By |2016-12-27T11:06:20-06:00July 25, 2016|

Internal Investigations in Healthcare—Assessing the Extent of the Misconduct and Preparing for an Internal Investigation

Misconduct in healthcare settings – whether accidental or through intentional and fraudulent action – can have significant consequences for the individuals and organizations involved. Criminal, civil, and administrative liability may be on the line, and an internal investigation of the misconduct may not only be required by corporate policy, but also by federal or state law.  Consequently, it is imperative [...]

By |2016-12-27T11:06:20-06:00June 23, 2016|

Labor Department Issues Final Rule Affecting Overtime

On May 18 the White House released the much-discussed and awaited details of the new Department of Labor overtime pay rules, raising the exempt threshold from $23,660 to $47,476 per year — under which most salaried workers are guaranteed overtime. The Department of Labor’s final rule updating the overtime regulations is expected to automatically extend overtime pay protections to more than 4 million workers within [...]

By |2016-12-27T11:06:24-06:00June 9, 2016|

CMS Updates Self-Referral Disclosure Protocol

The Centers for Medicare and Medicaid Services recently updated the Self-Referral Disclosure Protocol (SRDP), seeking to revise the currently approved information collection request that advises hospitals on how to disclose an actual or potential violation of the physician self-referral statute. As an additional update, CMS is also issuing a required form for SRDP submissions. CMS is seeking to revise the [...]

By |2016-12-27T11:06:24-06:00June 7, 2016|

Don’t Hit Reply: Why Your Company Could Violate HIPAA by Responding on Social Media

Does your health care company have a website, Yelp or Google profile, Facebook page, or a Twitter, Instagram or LinkedIn account? Do your patients have the ability to post or make comments on these different social media platforms? If you answered yes to both of these questions, your company should be concerned about potential exposure to the Health Insurance Portability [...]

By |2016-12-27T11:06:24-06:00May 23, 2016|

Medicaid and CHIP Beneficiaries Gain Parity Access for Mental Health and Substance Use Services

Medicaid and Children’s Health Insurance Program (CHIP) beneficiaries will receive greater access to mental health and substance use disorder benefits in the future based upon a final rule released on March 29 by the Centers for Medicare & Medicaid Services (CMS). In the final rule, CMS requires Medicaid and CHIP programs to deliver mental health and substance use services equal [...]

By |2016-12-27T11:06:25-06:00April 20, 2016|