GreisGuide to LTACHs » physician

Save the Date: NALTH 2011 Education Conference

Jason Greis — Mon, 10 Jan 2011 02:24:04 +0000

LTACH PHYSICIAN FOCUS
October 6-7, 2011
Omni Royal Orleans Hotel
New Orleans, Louisiana Read More...

ACOs and the Shared Savings Program: Some Common Misconceptions

Jason Greis — Sat, 02 Oct 2010 17:37:41 +0000

Section 3022 of the Patient Protection and Accountable Care Act (the Act) creates the Shared Savings Program for Medicare. Under the Shared Savings Program, which is to take effect no later than Jan. 1, 2012, Accountable Care Organizations (ACOs) that meet certain requirements established by the Secretary of Health and Human Services will be eligible to receive additional payments from Medicare where certain performance guidelines are met and cost-savings targets are achieved. The amount of the additional payment will be a percentage of the difference between the estimated per capita Medicare expenditures for patients assigned to the ACO and the cost-savings per capita Medicare expenditures threshold. Read More...

CMS Issues Proposed Rule on Changes to Stark In-Office Ancillary Services Exception

Jason Greis — Thu, 12 Aug 2010 22:47:28 +0000

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...

CMS Proposes Rule to Cross-Privilege Physicians Practicing Telemedicine

Jason Greis — Thu, 24 Jun 2010 00:50:56 +0000

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...

Exploring the Adverse Impact of Federal Healthcare Reform on Physician-Owned Hospitals

Jason Greis — Thu, 01 Apr 2010 23:27:16 +0000

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...

When MedPAC Speaks Congress Listens: What the Inclusion of MedPAC Health Care Delivery Reform Proposals in Health Care Reform Legislation Means for Physicians

Jason Greis — Sun, 28 Mar 2010 22:08:50 +0000

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...

McGuireWoods 8th Annual Business & Legal Issues in Dialysis & Nephrology Symposium

Jason Greis — Tue, 23 Feb 2010 05:22:44 +0000

[ May 12, 2010; 7:30 am to 5:30 pm. ] Wednesday, May 12, 2010 7:30 a.m. - 5:30 p.m. Westin Chicago O'Hare 6100 River Road Rosemont, Illinois 60018 Click here to reach the online registration form Save the date for an engaging full-day seminar covering business and legal issues in dialysis and nephrology. Geared toward nephrologists; hospital and dialysis facility CEOs, CFOs and COOs; lawyers; administrators; and consultants, the symposium will [...]

LTACH Medical Director and Medical Center Employees Receive Fines and Probation for HIPAA Violations

Jason Greis — Sat, 05 Dec 2009 14:49:13 +0000

In October 2009, a Federal judge in Arkansas sentenced the medical director of an Arkansas hospital-within-hospital LTACH and an account representative and emergency unit coordinator of the host hospital to fines and probation for violating the Health Insurance Portability and Accountability Act (“HIPAA”) by unlawfully viewing a high profile patient’s electronic medical records. (U.S. v. Holland, E.D. Ark., No. 09-cr-168, sentencing Oct. 26, 2009; U.S. v. Griffin, E.D. Ark., No. 09-cr-169, sentencing Oct. 26, 09; U.S. v. Miller, E.D. Ark., No. 09-cr-170, sentencing Oct. 26, 2009). Read More...

FTC Defers Enforcement of the Red Flags Rule to November 1, 2009

Jason Greis — Wed, 29 Jul 2009 23:13:06 +0000

On July 29, 2009, the U.S. Federal Trade Commission (FTC) deferred enforcement of the Red Flags Rule from August 1, 2009 to November 1, 2009 in order “to give creditors and financial institutions more time to develop and implement written identity theft prevention programs.” As we discussed in our articles from 4/27/09 and 5/4/09, the Red Flags Rule will require many businesses to develop, implement, and administer an Identity Theft Prevention Program that is designed to detect the warnings signs (or “red flags”) of identity theft, as well as to prevent and mitigate it. Read More...

OIG Bars Stark-Only Violations From Self-Disclosure Protocol

Jason Greis — Fri, 22 May 2009 19:08:33 +0000

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...