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.
Read MoreA Final Rule published by CMS makes several important changes to the Stark Law that will be a boon for physicians eager to more closely coordinate with other providers to (1) better manage patient care and (2) to participate in the shift to value-based reimbursement.
Read MoreOn December 1, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2021 (the “Final 2021 MPFS”), revising payment policies for services provided to Medicare beneficiaries by medical practitioners. These policies will take effect on January 1, 2021. Read on for insights from Team NGL.
Read MoreThe Office of the Inspector General for HHS released a Final Rule aimed at reducing regulatory barriers and facilitating the move towards value-based care and giving healthcare providers and digital health companies more flexibility to enter into new business arrangements. This article is a high-level overview of the Rule and what it may mean for the future of healthcare.
Read MoreOn August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released it Proposed Medicare Physician Fee Schedule for CY 2021 (“Proposed MPFS”), seeking to expand reimbursement for Virtual Check-ins and e-Visits as a way of improving access to patient care. CMS proposes seven new HCPCS codes for these “Communication Technology-Based Services” that could be billed by practitioners who cannot bill Evaluation and Management (“E/M”) services independently.
Read MoreCarrie Nixon, of the Nixon Law Group, said the order calls for “a strategy to improve rural health by improving the communications infrastructure in rural America,” though she notes such a strategy would have to be funded.
Read MoreLast evening, the Centers for Medicare & Medicaid Services (“CMS”) issued its proposed Medicare Physician Fee Schedule for CY 2021 (the “MPFS”). In addition to a number of important changes relating to the provision and reimbursement of telehealth, the proposed MPFS includes long-awaited clarifications around use of the Remote Patient Monitoring (“RPM”) codes established over the past three years
Read MoreNixon Law Group’s Managing Partner, Carrie Nixon, was quoted in an article appearing in Internet of Things World Today discussing the future of telehealth.
Read MoreNixon 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."
Read MoreExperts Weigh in on Post-COVID-19 Telehealth Rules and Policies. Nixon Law Group’s Managing Partner, Carrie Nixon, was quoted extensively in an article appearing in mHealth Intelligence regarding her views on post-COVID-19 telehealth rules and policies.
Read MoreThe Center for Medicare and Medicaid Services (“CMS”) has issued a second Interim Final Rule (“IFR2”) that includes additional expansions and clarifications relating to the provision and reimbursement of telehealth, remote patient monitoring, and telephone services during the COVID-19 Public Health Emergency (“PHE”). While these expansions are another step forward for the adoption of digital technologies and services in healthcare, there are additional changes needed in the near-term, as detailed in the summary below.
Read MoreThe Coronavirus Aid, Relief, and Economic Security Act (CARES Act) passed by Congress on March 27, 2020 opened the door for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to increase healthcare access to patients in rural and underserved areas by reimbursing for telehealth services to Medicare beneficiaries during the public health emergency (PHE). In addition, CMS has issued non-legislative policy changes and flexibility to address the increased need for remote services for Medicare beneficiaries in rural areas of the country.
Read More‘We'll likely need a legislative change for these changes to be permanent,’ said Nixon. ‘There will be more of an impetus now. Once patients have had telehealth, it's likely they won't want to go back.’”
Read MoreJoin us for a webinar to explain the most recent regulatory and reimbursement changes around the Remote Patient Monitoring, Telehealth, e-Visit, and Virtual Check-in CPT codes, during COVID-19, and what those changes mean from a practical perspective.
Read MoreIn response to urgent requests from healthcare providers and digital health services companies, CMS released an Interim Final Rule with comment period (the “Rule”) on March 30, 2020 that eases restrictions around the use of telehealth and other virtual communications technologies to aide response to the COVID-19 public health crisis. The Rule adds reimbursement for over 80 additional services that can now be furnished by telehealth, removes the requirement that Medicare patients have a previously established relationship with the provider billing for telehealth or remote communications services, and allows the “face-to-face” encounters required to initiate some services to be conducted via telehealth.
Read MoreWhen the Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020 was signed into law on March 6th, a provision in the Act that waives the geographic and originating site restrictions on telehealth services for the elderly garnered less attention, but could have a very important role to play in combatting COVID-19 - particularly if the waiver authority is further expanded by Congress. Learn more about the emergency telehealth waivers.
Read MoreHistorically, biometric data – think fingerprint scans to “clock in” and face recognition technology for identifying potential suspects – has been collected by employers, law enforcement, and financial institutions and used for security purposes. As technology evolves and becomes more sophisticated, private companies—including digital health, telemedicine, and RPM companies—are beginning to incorporate biometric data from consumers and patients into their solutions.
Read MoreThe 2020 Medicare Physician Fee Schedule (the “Final Rule”), released on November 1, 2019, finalized two new codes in a new category of reimbursement titled “Principal Care Management” (PCM) Services. The new codes will be effective as of January 1, 2020, and provide reimbursement for managing a patient’s care for a single high-risk disease or complex chronic condition.
Read MoreIn 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.
Read MoreThe Centers for Medicare and Medicaid Services (CMS) released the Final Medicare Physician Fee Schedule for CY 2020 (the “2020 MPFS”) on November 1, 2019. The 2020 MPFS finalizes six new CPT codes for e-Visits, providing new opportunities for physician practices to be reimbursed for conducting digital health assessments and evaluations for their patients and for remote patient monitoring companies to add these capabilities to their platforms.
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