OIG Warns That Manufacturer Safeguards May Not Prevent Copayment Coupon Use for Part D Drugs

0
Overview The Department of Health & Human Services Office of Inspector General (“OIG”) recently released a Special Advisory Bulletin on the fraud and abuse implications of pharmaceutical manufacturers offering copayment coupons to reduce or eliminate the cost of out-of-pocket copayments for brand-name drugs.  The Special Advisory Bulletin and the concurrent... Continue Reading →

Safe Harbors Less Safe in Ohio

0
In a new case from the Southern District of Ohio, US_v_MillenniumRadiology, the court denied a motion to dismiss a False Claims Act suit, finding that compliance with a safe harbor could only be raised on summary judgment. The court also found that uncompensated service as a medical director could form the basis... Continue Reading →

OIG Offers Glimpse of New Hospital-Patient and Physician Arrangements

0
The Department of Health and Human Services Office of Inspector General (“OIG”) recently issued a proposed rule that adds to and amends the Anti-Kickback Statute safe harbors and provides guidance regarding the Civil Monetary Penalty rules for beneficiary inducements and gainsharing (“Proposed Rule”).1 The Proposed Rule addresses several issues regarding... Continue Reading →

CMS Extends Publication Timeline of Final Rule for Waivers in Connection with the Medicare Shared Savings Program

0
Executive Summary On October 17, 2014, the Centers for Medicare & Medicaid Services (“CMS”) announced1 the extension of the November 2, 2011 interim final rule with comment that established waivers of some federal fraud and abuse laws as applied to Accountable Care Organizations (“ACOs”) participating in the Medicare Shared Savings... Continue Reading →

Ebola Preparedness – Take Steps Now to Ensure Health Care Workers and Hospitals Are Prepared to Care for Ebola Patients

0
Ebola concerns continue to grow this week as two nurses who cared for an Ebola patient in Texas test positive for the virus. Hospitals, physician offices, clinics, emergency medical services (“EMS”), physical therapy offices and other health care providers, regardless of location, need to prepare now for a possible Ebola patient. Care... Continue Reading →

This Week in Washington – October 17, 2014

0
Senator Urges Appropriators to Increase Hospital Preparedness Funding On October 13, Sen. Bob Casey (D-PA) asked the Senate Appropriations Committee to increase funding for the Hospital Preparedness Program (“HPP”) to $375 million in light of the Ebola outbreak spreading from West Africa. The HPP was authorized through the Pandemic and All-Hazards... Continue Reading →

Health Insurance Exchanges Round Two – Is It Time to Expand Your Charity Care Program Through a Premium Support Initiative?

0
WEBINAR As we move into the second year of open enrollment through the Health Insurance Exchanges, it is time to revisit the issue of Premium Support Programs, an issue that had a bit of a rollercoaster ride during last year’s open enrollment. Has the dust settled enough that you can... Continue Reading →

Selecting a Developer for Health Care Building Projects

0
Selecting the most qualified real estate developer for a health care development project starts with a properly conceived and structured Request for Proposal (“RFP”). Health care real estate projects typically have longer project timelines because there are numerous additional considerations involved in such projects. A properly crafted RFP requires thoughtfulness,... Continue Reading →

Tags: , , , , , , , , ,


Last Week in the FCA

0
From October 1 through October 12, 2014, there were 14 federal cases reported that mentioned the False Claims Act. One was previously discussed in the September 2014 FCA Update. Eight more only tangentially discussed the False Claims Act. Five cases might be of interest to parties and counsel in a False... Continue Reading →