Posted by Jason Greis on October 18, 2009 under Articles | 
Recent substantive and procedural amendments to the Federal False Claims Act (“FCA”) enacted under the Fraud Enforcement and Recovery Act of 2009 (“FERA”) are expected to fuel growth in the number of whistleblower-generated cases brought against healthcare providers—including LTACHs. The FERA amendments closed a loophole in the FCA that previously prevented overpayment cases from being brought against providers. The FCA now allows whistleblowers to bring false claims actions against providers who knowingly and improperly keep government funds paid to them in error. FERA was signed into law May 20, 2009. Read More...
Tags: allison engine, attorney general, claim, contractor, fera, fraud enforcement and recovery act, greisguide, greisguidetoltachs, health care, healthcare, hospital, intent, ltac, LTACH, LTCH, Medicaid, medicare, oig, supreme court
Posted by Jason Greis on May 22, 2009 under Articles |
Providers, including LTACHs and physicians, can no longer resolve potential Stark law-only violations through the HHS Office of Inspector General’s Provider Self-Disclosure Protocol, unless such violations are paired with Federal Anti-Kickback violations, according to the Office of the Inspector General’s recent open letter to providers. The letter, signed by Inspector General Dan Levinson, also notes that providers will no longer be able to get past the OIG’s front door in this context unless they anticipate a minimum kickback settlement amount of $50,000. Read More...
Tags: anti kickback, greisguide, greisguidetoltachs, hhs, hospital, levinson, ltac, LTACH, LTCH, oig, physician, provider, self-disclosure protocol, Stark, violation
Posted by Jason Greis on March 20, 2009 under Articles |
According to an audit report recently released by the Office of Inspector General of the Department of Health and Human Services (OIG), hospitals paid under the inpatient prospective payment system (IPPS) may have received an estimated $25 million in overpayments between fiscal years 2003 and 2005 as a result of noncompliance with Medicare’s post-acute transfer policy. The purpose of this policy is to provide a disincentive for hospitals to discharge patients to another hospital, a skilled nursing facility, or a patient’s home early in a patient’s stay in order to minimize costs while still receiving a full diagnosis-related group (DRG) payment. Read More...
Tags: 42 C.F.R. § 412.4(d), cms, drg, greisguide, greisguidetoltachs, home health, hospital, j. brian jackson, jason greis, ltac, LTACH, LTCH, mcguirewoods, medicare, oig, post-acute transfer policy, recoup, skilled nursing facility
Posted by Jason Greis on January 19, 2009 under Whitepapers |
I have recently spoken with a number of LTACH administrators and CEOs interested in entering into compensated call coverage arrangements or expanding the scope of their existing compensated call coverage programs with hospitalists, intensivists, and other physicians. Call coverage arrangements generally provide an excellent opportunity for LTACHs to align hospital and physician patient care objectives and for creating strategic long-term relationships with physicians in the community. These arrangements, however, also have the potential to adversely impact a hospital’s bottom line and raise a number of practical legal and business considerations discussed below that should be carefully considered. Read More...
Tags: 07-10, activation fee, advisory opinion, call coverage, double dipping, fair market value, fmv, greisguide, GreisGuide to LTACHs, hospital, hospitalist, intensivist, jason greis, LTACH, LTCH, medical staff, oig, on-call, patient, payor, physician, pulmonologist
Posted by Jason Greis on December 10, 2008 under Articles |
In the last year, there have been at least five health care fraud settlements in excess of $100 million each and total recoveries from health care providers in excess of $2 billion. Two of my colleagues recently authored an article titled “Pre- and Post- Commencement of an Investigation of Health Care Compliance: Key Considerations for All Providers.”The article discusses the means by which health care providers can minimize fraud allegations as well as mitigate damages in the event of a fraud investigation. Read More...
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