Posted by Jason Greis on November 29, 2009 under Articles | 
Effective October 1, 2009, the State of New York implemented regulations (18 N.Y.C.R.R §521.1) requiring all health care providers (including LTACHs) that receive more $500,000 from the Medicaid program in a year to adopt and maintain an effective compliance program. The effectiveness of a provider’s compliance program is to be judged by the N.Y. state commissioner of health and the Medicaid inspector general. Read More...
Tags: affiliate, board, compliance, greisguide, greisguidetoltachs, jason greis, ltac, LTACH, LTCH, New York, provider
Posted by Jason Greis on November 9, 2009 under Articles |
On Oct. 30, 2009, the U.S. Federal Trade Commission (FTC) deferred enforcement of the Red Flags Rule once again, from Nov. 1, 2009 to June 1, 2010, “at the request of Members of Congress.” However, the FTC also acknowledged that earlier that day, the U.S. District Court for the District of Columbia had enjoined the FTC from applying the Red Flags Rule to attorneys. Importantly, the FTC’s deferral does not affect the separate timeline of that legal proceeding and any possible appeals. Nor does this deferral affect other federal agencies’ ongoing enforcement for financial institutions and creditors subject to their oversight. Read More...
Tags: 2010, greisguide, greisguidetoltachs, healthcare, hospital, hr 3763, jonathan vogel, june, kenneth dort, kimberly kannensohn, larry goodall, ltac, LTACH, LTCH, mcguirewoods, provider, red flag rules
Posted by Jason Greis on October 18, 2009 under Articles |
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Tags: 3763, adler, bill, broun, creditor, greisguide, greisguidetoltachs, healthcare, hospital, house, jason greis, ltac, LTACH, LTCH, november 1, provider, red flag rules, simpson
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
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