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McBrayer Blogs
Showing 5 posts from November 2014.
HHS OIG RELEASES FISCAL YEAR 2015 WORK PLAN
Recently, the Office of Inspector General of the United States Department of Health and Human Services (“OIG”) released its Fiscal Year 2015 Work Plan summarizing its oversight and enforcement priorities for the 2015 Fiscal Year. Here are some highlights from the Work Plan. More >
Telehealth/Telemedicine: An Opportunity for Physicians and Providers to Add a New Line of Service
The cost effectiveness of providing health care via telemedicine or telehealth promises to be an effective tool to increase coverage and reimbursement of healthcare provided remotely or through telehealth. Towers Watson, a national consulting company, recently published a 2014 study that suggests that telemedicine could save $6 billion annually for the health care industry. "Achieving this savings requires a shift in patient and physician mindsets, health plan willingness to integrate and reimburse such services, and regulatory support in all states," according to Dr. Allan Khoury, a senior consultant at Towers Watson.[1] Recent studies have assigned significant cost savings generated by telehealth use that include cost savings of $537 million per year for emergency departments using telehealth to reduce transfers and spending reductions of 7.7% to 13.3% per person per quarter in the cost of care for chronically ill Medicare beneficiaries using a health buddy via telehealth. [2] As the cost effectiveness of providing services via telehealth and telemedicine is proven, Medicare, most state Medicaid programs and commercial insurers are increasing coverage as well as reimbursement for telehealth services. State law requirements for providing telehealth and coverage differ greatly. Consequently, physicians and health care providers should be aware of the complexity of providing telehealth and its requirements, but should also incorporate telehealth services into their practices as a new way of providing services and a new line of business. More >
The DOJ Increases Scrutiny of Whistleblower False Claims Act Suits
The Criminal Division of the Department of Justice (“DOJ”) recently announced that it will review all complaints filed under the qui tam provisions of the federal False Claims Act (“FCA”) to determine if a parallel criminal investigation is appropriate. This announcement came during a September 17, 2014 speech by the recently-confirmed Assistant Attorney General for the Criminal Division of the DOJ, Leslie Caldwell, at the Taxpayers Against Fraud Education Fund Conference in Washington D.C. This DOJ announcement signals a departure from prior policy, which allowed, but did not require, the Criminal Division to investigate Civil Division claims. In the past, the decision to open a criminal investigation was left to the discretion of each U.S. Attorney’s Office. More >
Kentucky Rural Health Clinics and FQHC’s/Look- A-Likes with Low Rates—Don’t Overlook this Rate Increase!
Approved by CMS and effective July 1, 2014, Kentucky’s Medicaid Program may now pay certain Rural Health Clinics (“RHC”), Federally Qualified Health Care Centers (“FQHC”) and Look-a-Likes a higher rate. The Department of Medicaid Services (“Medicaid”) sought approval to pay RHCs, FQHCs and Look-A-Likes that have a low per visit PPS rate at a rate equal to 125% of the Medicare rate. This means that Kentucky RHCs, FQHCs and Look-A-Likes with low Medicaid rates, just got a raise-- that is if they claim it! While the Medicaid State Health Plan Amendment provides that an “Alternative Payment Methodology” is now available, this really means that clinics with low rates can ask to be paid at a higher rate per visit without qualifying for a change in scope of service. This increase in rate is supposed to be effective on July 1, 2014, but is based upon the Medicare Upper Payment Limit for RHCs as of September 30, 2014 and the rate as we calculate it is approximately $99.70. Essentially, this means that providers with rates below the $99.70 threshold may elect to be paid under the alternative payment methodology. More >
Changes Proposed for Anti-Kickback Statute
It has been said before—healthcare is changing. Most often providers must adapt their practices to comply with governing regulations. Sometimes, governing regulations must be revised to adapt to providers practices. And on occasion, governing regulations must be revised to be consistent with other governing regulations. This is one of those occasions. More >
