The U.S. Departments of Health and Human Services, Labor and Treasury issued a final rule on February 9, 2012 requiring health insurers and group health plans to provide consumers with an easy-to-understand summary of benefits and coverage and a uniform glossary of commonly used health insurance terms. These disclosure requirements are intended to help those shopping for insurance, as well as those already enrolled in a plan, to make comparisons to better evaluate their health insurance coverage options. The Final Rule is slated for publication in the February 14, 2012 Federal Register. Continue reading
Monthly Archives: February 2012
HHS and Other Federal Departments Issue New Rule on Health Plans
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Posted in Consumers, DHHS, Final Rule, Group Health Plans, Health & Human Services, Health Care, Health Insurance, Health Reform, Payers, Regulation
OIG Alert: Physicians Should Exercise Caution When Reassigning Their Medicare Payments
On February 8, 2012, the Office of Inspector General (“OIG”) released an alert warning physicians to exercise caution when reassigning their right to bill and receive payment from the Medicare program. According to the OIG, Physicians who reassign their Medicare provider benefits by executing a CMS-855R application may be held liable for false claims submitted by the assignee. Continue reading
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Posted in Fraud and Abuse, Medicare, Out-Patient Care, Physicians, Primary Care, Program Integrity, Provider Enrollment - Medicare, Regulatory Compliance
CMS Issues Letter to State Agency Directors Changing Process for Initial Home Health Agency Enrollment
On December 23, 2011, CMS issued S&C: 12-15-HHA relating to changing the process by which State Agencies process home health agency initial certifications. The major change initiated with this guidance is that CMS has directed State Agencies to add an additional level of review to the initial certification process for home health agencies.
Activities Unrelated to the Medicare Shared Savings Program and Tax Exemption for ACOs
Last November, the IRS released Revenue Ruling 201145025 denying an application for tax-exempt status of an entity owned by a tax-exempt hospital (the “Entity”). The Entity primarily contracted with commercial payors to provide hospital services and physician services. The Entity’s activities are comparable to the activities an Accountable Care Organization (ACO) may conduct unrelated to the Medicare Shared Savings Program (the “Savings Program”), such as shared savings programs with commercial payors. The Revenue Ruling, therefore, provides additional guidance regarding the IRS’ concerns relating to the activities of ACOs that are unrelated to the Savings Program. Continue reading
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Posted in Accountable Care Organizations, Health Care, Health Care Providers, Health Reform, Integration, Medicaid, Medicare, Non-profit, Payers, Tax-Exempt
Benesch
Ari J. Markenson, JD, MPH
Janet K. Feldkamp RN BSN LNHA CHC JD
Robert W. Markette, Jr. CHC
W. Clifford Mull
Frank W. Carsonie
Daniel J. O'Brien
Benjamin J. Parsons
Meredith L. Rosenbeck
Alan E. Schabes
