Contact Us
Subscribe to this blog via RSS
Join us on LinkedInCategories
- Sexual Harassment
- Health Resource and Services Administration
- Litigation
- Medical Malpractice
- House Bill 333
- Senate Bill 79
- locum tenens
- Senate Bill 4
- Physician Prescribing Authority
- HIPAA
- Chronic Pain Management
- Prescription Drugs
- "Two Midnights Rule"
- 340B Program
- Hospice
- Kentucky minimum wage
- Minimum wage
- Skilled Nursing Facilities (“SNFs”)
- Uncategorized
- EHR Systems
- ICD-10
- Primary Care Physicians ("PCPs")
- Electronic Health Records (“EHR")
- Drug Screening
- Urinalysis
- Mental Health Care
- KASPER
- Affordable Insurance Exchanges
- Fraud
- Health Care Fraud
- HIPAA Risk Assessment
- Office for Civil Rights ("OCR")
- Qui Tam
- Stark Laws
- Kentucky’s Department for Medicaid Services
- Compliance
- Department of Health and Human Services (HHS)
- Kentucky Board of Medical Licensure
- Office of Inspector General of the United States Department of Health and Human Services (OIG)
- Physician Assistants
- HPSA
- Pharmacists
- Accountable Care Organizations (“ACO”)
- Certificate of Need ("CON")
- Federally Qualified Health Centers (“FQHCs”)
- Fee for Service
- Part D
- Rural Health Centers (“RHCs”)
- Telehealth
- Affordable Care Act
- Anti-Kickback Statute
- Centers for Medicare & Medicaid Services (“CMS”)
- Data Breach
- Electronic Protected Health Information (ePHI)
- False Claims Act
- Health Information Technology for Economic and Clinical Health Act (HITECH Act)
- Health Insurance Portability and Accountability Act of 1996 (HIPAA)
- Hospitals
- Medicaid
- Medicare
- Patient Protection and Affordable Care Act (“ACA”)
- Health Professional Shortage Area ("HPSA")
- Medical Staff By-Laws
- Medically Underserved Area ("MUA")
- Rural Health Clinic
- Alternative Payment Models
- Charitable Hospitals
- HRSA
- Limited Services Clinics
- Mid-Level Practitioners
- Kentucky Board of Nursing
- American Telemedicine Association (“ATA”)
- Criminal Division of the Department of Justice (“DOJ”)
- Health Care Fraud Prevention and Enforcement Action Team (“HEAT”)
- Qualified Health Care Centers (“FQHC”)
- Telemedicine
- Hydrocodone
- United States ex. Rel. Kane v. Continuum Health Partners
- Webinar
- APRNs
- Chain and Organization System (“PECOS”)
- Jimmo v. Sebelius
- Maintenance Standard
- Overpayments
- Agreed Order
- Drug Enforcement Agency ("DEA")
- Hinchy v. Walgreen Co.
- Vitas Innovative Hospice Care
- Douglas v. Independent Living Center of Southern California
- Emergency Rooms
- Enrollment
- Kentucky Senate Bill 7
- Medicare Part D
- Minors
- Re-validation
- Chiropractic services
- Clinical Laboratory Improvement Amendments of 1988 (“CLIA”)
- Ophthalmological services
- Physician Compare website
- Texting
- All-Payer Claims Database ("APCD")
- Compliance Officer
- ICD-9
- 2014 Medicare Physician Fee Schedule (“PFS”)
- 501(c)(3)
- Chronic Care Management
- Compounding
- CPR
- Drug Quality and Security Act (“DQSA”)
- Essential Health Benefits
- House Bill 3204
- New England Compounding Center ("NECC")
- Outsourcing facility
- Sustainable Growth Rate (“SGR”)
- Appeal
- Dispenser
- HealthCare.gov
- Kindred v. Cherolis
- Long-term care communities
- National Drug Code ("NDC")
- Ping v. Beverly Enterprises
- Power of Attorney ("POA")
- Prescriber
- State Health Plan
- Cadillac tax
- Centers for Disease Control and Prevention
- Denied Claims
- Federation of State Medical Boards (“FSMB”)
- Food and Drug Administratio
- Grace Period
- Individual mandate
- Kentucky Medical Practice Act
- Kynect
- Mobile medical applications ("apps")
- Model Policy for the Appropriate Use of Social Media and Social Networking in Medical Practice (“Model Policy”)
- NADSA Conference
- National Institutes of Health
- Physician Payments
- Qualified Health Plan ("QHP")
- Social Media
- Spousal coverage
- UPS
- Affinity Health Plan
- Community health needs assessment (“CHNA”)
- Condition of Participation ("CoP")
- Form 4720
- Home Medical Equipment Providers
- Inpatient Care
- Licensure Requirements
- Long-Term Care Providers ("LTC")
- Medicare Shared Saving Program (MSSP)
- Nonprofit hospitals
- Personal Service Entities
- “Superuser”
- "Plan of Correction"
- Arbitration
- Daycare centers
- Department of Medicaid Services’ (“DMS”)
- Division of Regulated Child Care
- Employer Mandate
- Fair Labor Standards Act (FLSA)
- Health Professional Shortage Areas (“HPSA”)
- Home Health Prospective Payment System
- Hospitalists
- Intermediate Sanctions Agreement
- Kentucky Health Benefit Exchange
- Licensed practical nurses (LPN)
- LLC v. Sutter
- Low-utilization payment adjustment ("LUPA")
- Network provider agreement
- Nonroutine medical supplies conversion factor (“NRS”)
- Nurse practitioners (NP)
- Payors
- Physician Recruitment
- Physician shortages
- Quality reporting
- Registered nurses (RN)
- Residency Programs
- Statement of Deficiency ("SOD")
- Upcoding
- Audit
- Decertification
- EHR vendor
- Employer Group Health Plans
- ERISA
- False Billings
- Health Reform
- List of Excluded Individuals and Entities
- Meaningful use incentives
- Medicare Administrative Coordinators
- Medicare Benefit Policy Manual
- Office of the National Coordinator for Health Information Technology (“ONC”)
- Part A
- Part B
- Provider Self Disclosure Protocol
- Self-Disclosure Protocol
- Trade Association Group Coverage
- Advanced Practice Registered Nurses
- Business Associate Agreements
- Business Associates
- Call Coverage
- Doe v. Guthrie Clinic
- Group Purchasing Organizations ("GPO")
- House Bill 104
- Kentucky House Bill 217
- Patient Privacy
- Personal Health Information
- Autism/ASD
- Kentucky House Bill 159
- Patient Autonomy
- Senate Bill 39
- Senate Finance Committee Report
- State Medicaid Expansion
- Genetic Information Nondiscrimination Act ("GINA")
- Kentucky Primary Care Centers (“PCCs”)
- Managed Care Organizations (“MCOs”)
- Compliance Programs
- Critical Access Hospitals (“CAHs”)
- Essential Health Benefits (“EHBs”)
- Medicare Audit Improvement Act of 2012
- Recovery Audit Contractors (“RAC”)
- Small Business Health Options Program (“SHOP”)
- Sunshine Act
- Abuse and Waste
- Center for Disease Control
- Consumer Operated and Oriented Plan programs (“CO-OPS”)
- Healthcare Information and Management Systems Society (HIMSS)
- Kentucky Health Cooperative (“KYHC”)
- Occupational Safety and Health Administration (“OSHA”)
- Kentucky Cabinet for Health and Family Services
- Kentucky Health Care Co-Op
- House Bill 1
- Kentucky Pharmacists Association
- Kentucky “Pill Mill Bill”
- Free Conference Committee Report
- Health Care Fraud and Abuse Control Program
- House Bill 4
- Pain Management Facilities
- Employee Agreement
- Health Insurance
- Healthcare Regulation
- Health Care Law
McBrayer Blogs
Showing 7 posts from July 2014.
Update: CMS Issues Revised Guidance on Hospice & Part D Prior Authorization Process
A few weeks ago, we discussed CMS’ newly-issued guidance establishing a prior authorization process for Hospice and Part D providers (read more here). As our previous blog post emphasized, soon after its March 10 implementation, advocacy groups, Hospice associations, and Members of Congress began urging CMS to suspend the process. According to opponents, the prior authorization requirement creates a barrier for beneficiaries to access necessary medications and leaves them to navigate complicated payor disputes in the midst of their terminal illnesses. More >
Labs & Referring Physicians Take Note of OIG’s Special Fraud Alert
Recently, the U.S. Department of Health & Human Services, Office of Inspector General (“OIG”) issued a Special Fraud Alert (“Alert”) entitled, “Laboratory Payments to Referring Physicians.” The Alert focuses on (1) Specimen Processing Arrangements and, (2) Registry Arrangements. These arrangements, according to the OIG, pose substantial risks for fraud and abuse under the federal Anti-Kickback Statute. More >
New Part D Regulations Face Increased Scrutiny from Advocacy Groups & Congress
On March 10, 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum to Part D Plan Sponsors and Medicare Hospice Providers entitled, "Part D Payment for Drugs for Beneficiaries Enrolled in Hospice – Final 2014 Guidance" (“Guidance”). The Guidance, effective since May 1, 2014, requires a prior authorization process for Hospice and Part D providers to determine their respective responsibility for drug coverage. The Guidance followed a 2012 OIG report entitled "Medicare Could Be Paying Twice for Prescription Drugs for Beneficiaries in Hospice,” which found that Medicare Hospice patients’ medications were sometimes paid for by Part D rather than by the patient’s Hospice program. More >
New Law Affecting APRNs Takes Effect Today
Today, Senate Bill 7, signed by Governor Beshear on February 26, 2014, becomes effective. The new law allows for an Advanced Practice Registered Nurse (“APRN”) to request to discontinue a Collaborative Agreement for Prescribing Authority for Non-Scheduled drugs (“CAPA-NS”) after having a CAPA-NS in place for four years. Specifically, the new law states: More >
Have You Reviewed Your Existing Business Associate Agreements?
Pursuant to the HIPAA Final Omnibus Rule (“Final Rule”), covered entities and their business associates were required to enter into new business associate agreements (“BAAs”) or modify existing BAAs by Sept. 23, 2013. However, existing BAAs that (i) were entered into on or before Jan. 25, 2013; (ii) met the requirements that were applicable prior to the promulgation of the Final Rule; and (iii) were not modified after March 26, 2013, have until Sept. 23, 2014 to be updated. That deadline is quickly approaching. More >
OCR Offers “Lessons Learned” Regarding HIPAA Compliance, Part II
On Tuesday, some of the details of OCR’s recently released Breach and Compliance Reports were discussed. In addition to detailing facts and figures from cases involving breaches in 2011 and 2012, the Breach Report includes an important “Lessons Learned” section that all covered entities and their business associates should review. Based upon reported breaches, the OCR has outlined some specific areas of concern, which include the following: More >
OCR Offers “Lessons Learned” Regarding HIPAA Compliance
Two recent reports issued by the HHS Office for Civil Rights (“OCR”), pursuant to the HITECH Act, reveal some interesting information about HIPAA data breaches. The Annual Report to Congress on Breaches of Unsecured Protection Information (“Breach Report”) and the Annual Report to Congress on HIPAA Privacy, Security, and Breach Notification Rule Compliance (“Compliance Report”) should remind covered entities and their business associates about the many risks associated with HIPAA and the importance of compliance. More >
