Time Period to Submit Medicare Claims Is Shortened to Twelve Months

The proposed Medicare Physician Fee Schedule for 2011 (PFS) includes a proposal that Medicare fee-for- services claims for services furnished on or after January 1, 2010, must be filed within one calendar year after the date of services. This proposal by CMS is aimed at implementing Section 6404 of the Affordable …

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Just Released: Model Claims Notices and External Review Guidance

The DOL has released three model notices in connection with the recent rules on internal claims and appeals and external review processes.  The notices cover internal benefit determinations and external review decisions: Model Notice of Adverse Benefit Determination Model Notice of Final Internal Adverse …

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Proposed CMS Rule Would Require Group Practices to Notify Medicare Beneficiaries of Alternative Advanced Imaging Suppliers

Section 6003 of the Patient Protection and Affordable Care Act (PPACA) amended the Stark Law in-office ancillary service exception as applied to physician practices furnishing MRI, CT, PET, and potentially other diagnostic imaging services. The Stark Law prohibits a physician from making a referral for certain …

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Eighth Circuit Issues Decision on Bundling and Exclusive Dealing

The Eighth Circuit has issued a significant antitrust decision addressing bundled rebates and the law surrounding exclusionary contracts. In Southeast Missouri Hospital v. C.R. Bard, Inc. (No. 09-3325, Aug. 17, 2010), the Eighth Circuit affirmed the district court's grant of summary judgment dismissing a …

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Can a new early retiree medical plan apply for certification under the Early Retiree Reinsurance Program?

Since June 29, 2010, the Department of Health and Human Services (HHS) has been accepting applications for plan certification under the Early Retiree Reinsurance Program (ERRP).  Some plan sponsors that previously did not provide any group health benefits to early retirees are now thinking about starting to offer …

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CMS’ Confusion Over LTCF Dialysis Continues

CMS permits home dialysis in a long-term care facility (“LTCF”)—that much is clear.  But that is about as much clarity as there is, and the newly released Final Prospective Payment System (“PPS”) rule for End Stage Renal Disease (“ESRD”) does not make things much better. In 2004, CMS issued two …

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