CMS has released four new FAQs regarding the applicable reopening period and “look back” period for potential Stark violations disclosed through the voluntary Self-Referral Disclosure Protocol (SRDP). The new FAQs clarify that a disclosing party may limit both (i) its disclosure of the total amount of …
Top 10 Lessons From The Bradford Regional Case
March 17, 2011 Leave a Comment
If you have not done so already, you should read the court’s opinion in United States ex rel. Singh v. Bradford Regional Medical Center, No. 04-186 (W.D. Pa. Nov. 10, 2010). The case examined an arrangement between Bradford Regional Medical Center (Hospital) and Drs. Vaccaro and Saleh and their practice entity …
Physician Fraud and Abuse Guidelines: Starting Young
November 23, 2010 Leave a Comment
According to an Office of Inspector General (OIG) study, less than half of all U.S. medical schools provide training on Medicare and Medicaid fraud and abuse laws. Further, the OIG study found that only two-thirds of residency and fellowship programs reported providing their residents or fellows with any …
Final Rule Requiring Group Practices to Notify Medicare Beneficiaries of Alternative Advanced Imaging Suppliers
November 18, 2010 Leave a Comment
Section 6003 of the Patient Protection and Affordable Care Act (PPACA) amended the Stark Law in-office ancillary services exception as applied to physician practices furnishing advanced imaging services, such as MRI, CT, PET, and potentially other diagnostic imaging services, by adding a disclosure …
Alternative Suppliers Notification Requirement: Do Hospitals Have to Comply?
September 23, 2010 Leave a Comment
As we discussed in a previous post, Section 6003 of the Patient Protection and Affordable Care Act (PPACA) requires physician groups relying on the “in-office ancillary services” exception to the Stark Law for referrals of MRIs, PET scans and CTs to let patients know of other options to obtain these services. …
CMS Issues Voluntary Self-Referral Disclosure Protocol
September 23, 2010 Leave a Comment
Today CMS issued its voluntary self-referral disclosure protocol (SRDP) as required under Section 6409 of the Patient Protection and Affordable Care Act (PPACA). Section 6402 of PPACA requires certain providers, suppliers and other entities to report and return overpayments by the later of (i) 60 days after the …