Category Archives: Quality Improvement

OIG Advisory Opinion 12-22 – No Sanctions Imposed For Hospital’s Bonus Payments to Physician Group

On December 31, 2012, the OIG issued a favorable Advisory Opinion, No. 12-22, concerning a cardiology co-management agreement between a hospital and a private cardiology group practice (the “Management Agreement”).  Although the  Management Agreement potentially implicates the Anti-Kickback Statute and includes bonuses provided to a physicians’ group in exchange for implementing quality-improvement and cost-saving measures at the hospital’s cardiac catheterization laboratories (the “Arrangement”), the OIG advised that it would not impose sanctions on the requesting parties under the Civil Monetary Penalty or the Anti-Kickback Statute.  Continue reading

CMS Issues 2012 Nursing Home Action Plan

The Centers for Medicare and Medicaid Services (CMS) recently announced the issuance of the 2012 Nursing Home Action Plan (S&C:12-39-NH).  The 39 page action plan focuses on goals of further improvement of nursing home quality.    The plan outlines three objectives:  1) better care for individuals; 2) better health for the populations; and 3) lower cost through improvement.  Continue reading

CMS Issues Proposed Rule on Rights of Beneficiaries to Make Complaints to Quality Improvement Organizations (QIOs)

On February 2, 2011, the Centers for Medicare and Medicaid Services (“CMS”) issued a proposed rule in the Federal Register, 76 FR 5755, that requires most Medicare providers and suppliers to provide written notice to beneficiaries of their right to lodge quality of care complaints with Quality Improvement Organizations (QIOs).

CMS contracts with a QIO in each state. QIOs are mostly private organizations staffed by health care professionals that CMS has trained to review the quality of medical care, help Medicare beneficiaries with complaints about care, and to implement improvements in the quality of care provided by Medicare providers and suppliers. CMS’ mission for the QIO Program is to improve the effectiveness, efficiency, economy, and quality of services delivered to Medicare beneficiaries. Continue reading