The IOM Recommends That the Current GME Reimbursement System Is Overhauled – Are You Prepared to Weather the Storm?

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The recent report by the Institute of Medicine on the United States graduate medical education system, Graduate Medical Education That Meets the Nation’s Health Needs1 (“IOM Report”), advances many structure reform themes that have appeared in other assessments in recent years.  However, it goes much further.  The IOM Report calls... Continue Reading →

Reasonable Accommodation – Just Assign Wheelchair Transport Duties to an Orderly?

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Was Job Restructuring Reasonable?  The Jury Will Decide A hairdresser at a nursing home quit her job following surgery when her boss failed to consider assigning her duties of transporting wheelchair bound residents to the beauty salon to orderlies.  She filed an ADA suit claiming a failure to reasonably accommodate... Continue Reading →

False Claims Act Update – Public Disclosure and Original Source

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Several FCA opinions have been issued since the last FCA Update. The most interesting is a District of Nevada case, US ex rel Guardiola v Renown Health. Renown Health was the parent company for two other corporate defendants that provided acute health care services. The relator was Renown’s Director of Clinical Compliance. She... Continue Reading →


Private Use Overhaul: IRS Expands Rev. Proc. 97-13 Safe Harbors; Provides Guidance for Participation in ACOs

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On Friday, October 24, 2014, the IRS released an advance version of Notice 2014-67, (1) adding a new 5-year safe harbor to Revenue Procedure 97-13 (“Rev. Proc. 97-13″) and providing for the inclusion of quality-based incentive payments in management and service contracts for facilities financed with tax-exempt bond proceeds; and (2)... Continue Reading →

This Week in Washington – October 24, 2014

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HHS Announces $840 Million in Quality Improvement Grants On October 23, CMS announced the CMS Innovation Center will grant $840 million to hospitals and doctors to provide improved care while reducing costs. The grants will support 150,000 clinicians over four years with incentives, tools and information as part of the ongoing... Continue Reading →

Ebola Preparedness – Important Takeaways from the October 21, 2014 Livestream Session

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As the first quarantine period in Texas passes without additional infections, the focus is on improving preparedness for Ebola while ensuring accurate information is made available to the public. To support preparedness efforts, the CDC and other health care organizations have taken steps to provide health care organizations and providers around... Continue Reading →

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Medigap Insurers May Negotiate Discounted Inpatient Deductibles and Pass Along the Savings to Policyholders

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Executive Summary In recently issued, virtually identical Advisory Opinions Nos. 14-07 and 14-08, the Department of Health and Human Services Office of the Inspector General (“OIG”) opined that licensed insurers offering Medigap policies to Medicare beneficiaries may contract with preferred hospital organization network hospitals for discounted Medicare inpatient deductibles and,... Continue Reading →

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

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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 →