On March 14, 2019, CMS issued “Technical Corrections” to address errors in the 2019 Final Medicare Physician Fee Schedule (“MPFS”) published on November 23, 2018. One of these corrections addresses “incident to” billing by clinical staff, and has important implications for Remote Patient Monitoring under CPT Code 99457.
Having written a series of posts over the years addressing employment contracting from the physician perspective, one of our readers reached out to let us know that Nixon Law Group should, likewise, address physician/clinician employment contracting from the perspective of the healthcare employer. Considerations for Clinician Contracting – An Employer Perspective…
This Advisory Opinion demonstrates OIG’s willingness to remove barriers to adoption of healthcare technologies - such as lack of access to a smartphone - that may improve patient outcomes and reduce overall costs of care.
Smart physicians are not immune from making highly regrettable mistakes when it comes to employment contracts. And unlike in medicine, you don't get the option of trying a new treatment plan if the first one doesn't work. Physicians are educated, and intellectually sophisticated. This means that, even though you weren’t trained to read legal contracts in medical school, courts expect that you have read and fully understand the terms of the contracts you sign. That means that, both during and even after your employment, you're stuck with the contract you sign, so make sure you avoid these common pitfalls.
On January 9, the 2019 General Assembly Session will convene, and there are several bills that are set to be introduced that may have an impact on Virginia healthcare providers. We will update this post with additional legislation as session progresses.
On December 12, 2018, Congress passed the 2018 Farm Bill (The “Agriculture Improvement Act of 2018” or the “Bill”), which includes provisions that exempt Cannabis plants with lower than 0.3% THC content (also called “Hemp”) from the Controlled Substances Act (CSA). Once signed into law, the Farm Bill effectively legalizes the production, commercialization, and interstate shipment and sale of hemp and hemp-derived products like cannabidiol or “CBD”. Each state (including Indian Tribes and U.S. Territories) will eventually be able to regulate hemp production like any other agricultural commodity, as long as the U.S. Department of Agriculture (USDA) approves its plan to monitor and regulate the plant’s production.
Beginning January 1, 2019, physicians and other Qualified Healthcare Providers (“QHCPs”) eligible to independently bill for E/M services can obtain standalone reimbursement for Interprofessional Internet Consultations using CPT Codes 99446-99449, 99451, and 99452.
The final 2019 Medicare Physician Fee Schedule (the “Rule”), released on November 1st, creates three new codes in the category of Chronic Care Remote Physiologic Monitoring (“CCRPM”) for (1) initial set-up and patient education, (2) initial device supply, and (3) monitoring data and interacting with patients or caregivers.
The final 2019 Medicare Physician Fee Schedule, released by CMS on November 1, 2018, includes a new code that physicians may use to bill for remote evaluation of images to determine whether or not an in-person office visit is necessary. Learn more about HCPCS Code G2010 and how it can be used in medical practices.
In its Final Rule for the 2019 Medicare Physician Fee Schedule released on Friday, CMS introduced a new code, HCPCS G2012, allowing physicians and other qualified healthcare professionals (“QHCPs”) to be reimbursed for “virtual check-ins” with patients who aren’t sure whether or not their symptoms warrant an in-office visit. Learn more about virtual check-ins and how they can be used by practices.
On September 27, 2018, the Department of Justice (“DOJ”) for the first time announced its own “road map” guiding voluntary self-disclosures and cooperation with government investigations of fraud and abuse in the healthcare industry. By encouraging self-disclosure, the government is incentivizing healthcare entities to come forward early with reports of violations in the hope of negotiating reasonable settlements, avoiding exclusion from Federal healthcare programs, and reducing the severe civil and criminal penalties that would otherwise be imposed for such violations.
“Do I really need a healthcare attorney? The Board is simply asking me to answer some questions and provide some documentation. Of course, a Board complaint is a big deal, but this part seems harmless/easy enough. I will just respond and tell them what happened, right?” The reality is that an effective response is not as straightforward as it may seem. Hiring a healthcare attorney to assist in the preparation of your response to a complaint investigation can improve your chances of resolving the complaint at the investigation stage, incidentally saving you money in the long run.