CMS Holds Webinar Explaining Open Payments Phase I

Yesterday, February 25th, CMS hosted a webinar titled, “Open Payments Phase 1 of 2 - Overview of Industry Data Registration & Data Submission.”  As the name implies, it discussed the various aspects of the Phase I, which requires applicable manufacturers to submit aggregate data on transfers of value to …

[Read more...]

CMS Delays Implementation of the Two-Midnight Rule – Will the Third Time Be the Charm?

Last week, in response to a continued outcry from hospitals, physicians and patient advocacy groups, CMS decided to delay implementation of the controversial two-midnight policy for inpatient stays for a third time.  The policy was scheduled to go into effect at the end of March but this latest delay has pushed …

[Read more...]

Open Payments Registration – Let the Fun Begin

It’s really happening, and fast.  On Friday, February 7th, CMS issued a notice (here) announcing that registration for Open Payments would begin on February 18th, and also surprised us with a two-phase process not provided for in the final rule.  The oft-delayed Federal Physician Payment Sunshine Act and …

[Read more...]

CMS and OIG Announce Plan To Exclude “Recalcitrant Providers”

In a move that made little immediate splash, but has since received considerable media attention, including a recent article in the New York Times, the Department of Health & Human Services announced that it will take additional steps against “recalcitrant providers,” including exclusion from participation …

[Read more...]

Sunshine – Lessons From the First Two Months of Tracking Payments

The first two-plus months of tracking payments under the Physician Payment Sunshine Act are now in the rearview mirror.  Though novel questions continue to arise (albeit with less frequency), CMS has attempted to keep up, offering additional FAQs.  Several of the more recent FAQs are of particular interest to …

[Read more...]

OIG Provides Insight Into New Self-Disclosure Protocol

In April, the U.S. Department of Health & Human Services’ Office of Inspector General (OIG) released an updated Provider Self-Disclosure Protocol (SDP) (here).  The revised SDP supersedes the original SDP issued in 1998 (here), and incorporates a series of open letters issued by OIG in 2006 (here), 2008 …

[Read more...]