Posted by Jason Greis on October 17, 2010 under Articles | 
The Patient Protection and Affordable Care Act (PPACA) requires the Secretary of the Department of Health and Human Services (HHS), with the Office of the Inspector General (OIG) of HHS, to establish a protocol for healthcare providers and suppliers to disclose actual or potential violations of Section 1877 of the Social Security Act (Stark Act). Under the Stark Act, healthcare providers and suppliers may not refer patients to any entity for certain services if the physician has a financial relationship with that entity, unless an exception for such referral applies. Read More...
Tags: cms, greisguide, greisguidetoltachs, long term acute care hospital, long term care hospital, ltac, LTACH, LTCH, mcguirewoods, post-acute, self-referral disclosure protocol, srdp, Stark, voluntary
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 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 6, 2009 under Whitepapers |
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Tags: designated health services, dhs, exception, financial relationship, greisguide, greisguidetoltachs, installment payment, jessica smith, ji hye kim, leasing, lithotripsy, ltac, LTACH, LTCH, mission support, non-monetary compensation, per click, percentage based, physician, professional courtesy, publicly traded company, referral, retention, scott becker, Stark
Posted by Jason Greis on February 5, 2009 under Articles |
President Obama signed the State Children’s Health Insurance Program bill into law on Wednesday, February 4, 2009, which will eable approximately seven million children to continue to have medical coverage through the program, and which will also allow an additional four million to sign up. President Obama called the bill “a first step toward fulfilling a campaign pledge to provide insurance for all Americans.” Read More...
Tags: cms, grassley, greisguide, greisguidetoltachs, hospital, investment, jason greis, kennedy, kohl, ltac, LTACH, LTCH, mccaskill, obama, ownership, pass, Physician Payments Sunshine Act, physician-owned hospital, schip, Stark
Posted by Jason Greis on January 27, 2009 under Articles |
On January 14, 2009 the House of Representatives voted to reauthorize the State Children’s Health Insurance Program (“SCHIP”). The House version of the SCHIP bill (HR 2) includes a provision contained in Section 623 proposed by House Ways and Means Health Subcommittee Chairman Fortney Pete Stark that would prevent construction of new physician-owned hospitals and restrict the expansion of current physician-owned hospitals by amending certain provisions of the Federal physician self-referral law (commonly known as the “Stark Act”). Congressman Stark has said that the provision banning future physician ownership in hospitals would prevent the “unethical kickbacks that physicians receive from ownership in hospitals, most of which are of questionable safety and quality.” This legislation, if passed, would significantly impact current physician ownership and investment interests in LTACHs (e.g., investment by physician joint venture partners) and specialty hospitals and would altogether ban future physician investment and ownership in LTACHs and specialty hospitals. Read More...
Tags: altha, cms, greisguide, GreisGuide to LTACHs, hospital, house, hr 2, investment, jason greis, LTACH, LTCH, nalth, ownership, pha, physician, physician hospitals of america, s 275, schip, senate, specialty hospital, Stark, State Children's Health Insurance Program
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