Posted by Jason Greis on August 12, 2010 under Articles | 
Section 6003 of the Patient Protection and Affordable Care Act, Public Law 111-148 (H.R. 3590) (PPACA) makes a change to the “in-office ancillary services” exception to the Stark physician self-referral law that impacts physician practices providing certain radiology services in their offices. In short, the change requires physicians making a referral for magnetic resonance imaging (MRI), positron emission tomography (PET), and computed tomography (CT), or certain other radiology services in their offices, to make a disclosure to the patient that such services can be provided elsewhere and to include a list of alternative providers. Read More...
Tags: brent rawlings, ct, david wolff, doctor, greisguide, greisguidetoltachs, in-office ancillary services exception, long term care hospital, ltac, LTACH, LTCH, mcguirewoods, mri, pet, physician, ppaca, tom stallings
Posted by Jason Greis on June 23, 2010 under Articles |
Telemedicine consultations are often provided by physicians at large hospitals, often called “distant-site” hospitals (See § 1834(1)(m)(4)(A) of the Social Security Act), to patients at smaller ones, such as those in rural areas. Physicians providing these consultations are privileged and credentialed at their home institutions, but often not, at the outset, at the hospitals to which they provide their advice electronically, which for purposes of this discussion, we refer to as local hospitals. Read More...
Tags: cms, doctor, greisguide, greisguidetoltachs, joseph mcmenamin, ltac, LTACH, LTCH, mcguirewoods, melissa gilmore, physician, privilege, telemedicine
Posted by Jason Greis on April 1, 2010 under Articles |
After almost a year of heated debate, President Obama signed into law the Patient Protection and Affordable Health Care Act (P.L. 111-148) (“PPACA” or the “Act”) on March 23, 2010, as amended by the Health Care and Education Affordability Act of 2010 (H.R. 4872) (“HCEAA”) on March 30, 2010. While many of these laws’ provisions are benign, some contain “bombshells” that will permanently alter the business and regulatory landscape for certain businesses. One such provision is contained in Section 6001 of PPACA, which significantly curbs physician ownership and investment in hospitals by restricting application of the Federal Ethics in Patient Referrals Act’s (the “Stark Law”) statutory “whole-hospital exception.” Read More...
Tags: doctor, Health Care and Education Affordability Act of 2010, investment, jason greis, long term care hospital, ltac, LTACH, LTCH, mcguirewoods, ownership, P111-148, patient protection and affordable health care act, physician, physician-owned hospital, poh, ppaca, shayna bowen, specialty hospital, Stark, whole-hospital exception
Posted by Jason Greis on March 28, 2010 under Articles |
On March 1, 2010, the Medicare Payment Advisory Commission (“MedPAC” or the “Commission”) released its 2010 Report to the Congress: Medicare Payment Policy (the “Final Report”) recommending annual Medicare payment updates for Medicare fee-for-service (“FFS”) payment systems, including among others, hospitals (including both general acute care and long term care hospitals) and physicians. MedPAC is an independent congressional agency established by the Balanced Budget Act of 1997 to formulate recommendations to Congress to address quality and cost-containment issues affecting the Medicare program and its beneficiaries. Two reports, issued in March and June each year, are the primary outlets for MedPAC’s policy and payment system updates, which change base rates paid by Medicare for a unit of service provided by a FFS provider—for example, a hospital admission or a physician visit or procedure. Recommended payment system updates are based on an assessment of payment adequacy that takes into account beneficiaries’ access to care, supply of providers, quality of care, providers’ access to capital and Medicare margins. Read More...
Tags: bundling, CBO, cms, doctor, equipment utilization assumption rate, ffs, grassley, greisguide, greisguidetoltachs, Health Care and Education Affordability Act of 2010, hhs, hr 4691, imaging, independent payment advisory board, ipab, jason greis, long term acute care hospital, long term care hospital, ltac, LTACH, LTCH, medicare, Medicare Payment Advisory Commission, MedPAC, obama, Patient Protection and Affordable Care Act, pha, physician, physician-owned hospital, primary care physician, radiologist, sgr, sustainable growth rate, tort reform
Posted by Jason Greis on March 16, 2009 under Articles |
On March 6, 2009, the Centers for Medicare and Medicaid Services (CMS) released a CMS Manuals System transmittal implementing a final rule from the hospital inpatient prospective payment system (IPPS) for fiscal year 2008 requiring disclosure of physician ownership or investment in physician-owned hospitals. Effective June 8, 2009 Medicare-participating hospitals will be required to disclose physician ownership or investment information to patients when a referring physician (or his or her immediate family members) has an ownership interest in a hospital. Physicians also will be required to disclose their ownership or investment interests (and the ownership or investment interests of their immediate family members) in all physician-owned hospitals to which a physician refers patients. A physician’s ownership or investment interest may be through equity, debt, or other means, and includes an interest in any indirect entity that holds an ownership or investment interest in a hospital. Read More...
Tags: agreement, cms, disclose, disclosure, doctor, greisguide, greisguidetoltachs, hospital, jason greis, ltac, LTACH, LTCH, medical staff, ownership, physician, physician-owned, privileges
Posted by Jason Greis on February 10, 2009 under Articles |
The below article was recently written by my colleague, Bart Walker, and was posted on the North Carolina Healthcare Report weblog. The article provides a cautionary tale to LTACHs and physicians alike of the types of criminal penalties available to the government for committing Medicare or Medicaid fraud. Read More...
Tags: abuse, awad, bart walker, court, criminal, doctor, fraud, hospital, ltac, LTACH, LTCH, medi-cal, Medicaid, medicare, north carolina healthcare report, physician, prison
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