Health Law Alert

On December 14, 2018, OCR issued a Request for Information (“RFI”) asking how HIPAA can be revised to better promote care coordination and value-based care while preserving privacy and security protections. The RFI is relatively short, and easily digestible. It categorizes its requests into four topic areas, asking more specific […]

On October 26, 2018, a new version of the National Practitioner Data Bank Guidebook was published by the Health Resources and Services Administration (HRSA), replacing the prior version published in April 2015. As background, hospitals and other health care entities are required to report adverse clinical privileges actions to the […]

Two recent developments from CMS related to provider-based departments: Payment Rates for Off-Campus Provider-Based Hospital Departments Paid Under the PFS Section 603 of the Bipartisan Budget Act of 2015 changed the reimbursement source for certain items and services furnished by some off-campus hospital outpatient provider-based departments. The change was to […]

In November 2018, CMS issued its final rule for the Medicare Physician Fee Schedule. In a previous article, we had summarized the changes to E&M coding that CMS had proposed in its July 27, 2018 proposed rule. In this final rule, CMS delayed until 2021 any changes to reimbursement for […]

While the volume of Resolution Agreements coming out of OCR in 2018 have been significantly less than in prior years (five thus far in 2018 versus 10 for the same period in 2017), with each Resolution Agreement, OCR continues to send very strong messages to covered entities and there are […]