Discover what the OIG found when investigating telehealth billing fraud, what they recommend regarding future CMS oversight, and four takeaways for businesses billing Medicare telehealth services.
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On January 13, 2022, in response to numerous legal challenges premised on the lack or abuse of executive authority.
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Find out what Healthcare and Life Sciences businesses and investors anticipate for the healthcare industry in 2022.
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On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Medicare Physician Fee Schedule for Calendar Year 2022 (the “Final 2022 MPFS” or the “Final Rule”). As we noted in our July article discussing the Proposed 2022 MPFS, CMS made some significant proposed changes to allow for audio-only telehealth in some limited circumstances. In addition, the agency also proposed to enable remote “direct supervision,” which would allow practitioners to supervise clinical staff billing incident to their services as long as they could be available by audio/video communication as necessary.
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In the Final Medicare Physician Fee Schedule (“MPFS”) for 2022 (the “Final Rule”) issued on November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) added five new CPT codes in the categories of Chronic Care Management (“CCM”) and Principal Care Management (“PCM”) and increased reimbursement for already existing codes in the same categories. Despite stakeholder feedback, CMS refrained from making any changes to the existing rules for obtaining beneficiary consent for CCM and PCM.
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On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2022 (the “Final 2022 MPFS”), revising certain payment policies for services provided to Medicare beneficiaries by healthcare practitioners. These policies take effect on January 1, 2022.
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We’ve hit the record button during our weekly Partner meeting to talk about the increased scrutiny of telemedicine and virtual care service by the Office of the Inspector General (OIG), as reflected in the latest OIG work Plan and ongoing audits and evaluations.
This conversation is especially relevant for those of you in the telehealth/digital health space, whether you’re a healthcare provider or platform/tech providers.
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Dramatic changes to the Anti-Kickback Statute and the Stark Physician Self-Referral Law regulations present an unprecedented opportunity for healthcare providers and digital health companies to create new business arrangements that align incentives around care coordination and patient engagement. Such arrangements are the foundation of the Value-Based Enterprise.
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Nixon Law Group’s Managing Partner, Carrie Nixon, was quoted in an op-ed for The Hill discussing 5 actions to fuel the digital health momentum. "The COVID-19 public health emergency has forcefully opened the door for widespread adoption of telehealth, remote patient monitoring, and other digital health platforms by patients and providers alike."
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In this article on the proposed changes to the fraud and abuse regulations, we focus on OIG’s proposed Patient Engagement and Support safe harbor to AKS and CMP and discuss how this new safe harbor may affect care management services vendors such as Chronic Care Management (CCM), Remote Patient Monitoring (RPM), Transitional Care Management (TCM), and Behavioral Health Integration (BHI) services vendors.
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In this article, we focus on the proposed Care Coordination Arrangements safe harbor to the Anti-Kickback Statute and discuss how this new safe harbor may affect vendors of care management services such as Remote Patient Monitoring, Chronic Care Management services, Transitional Care Management services, and Behavioral Health Integration services.
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