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Wachler & Associates Health Law Blog

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Recent RAC Updates

CGI Federal, RAC for region B, has recently added a new issue to its CMS-approved issue list for providers in all region B states. Pharmacy Supply Dispensing Fee. Medicare pays pharmacy supply/dispensing fees for immunosuppressive, oral anti-cancer, chemotherapeutic, and oral anti-emetic drugs as well as drugs used as part of…

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CMS Announces the Creation of Its Advance Payment Model

On October 20, 2011, the Centers for Medicare and Medicaid Services (CMS) released its final rule for Accountable Care Organizations (ACO) participation in the Medicare Shared Savings Program. With this rule, in response to concerns related to start up costs associated with ACOs, CMS has also announced the creation of…

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20 Notable Aspects of the Final ACO Rule

On October 20, 2011, CMS released the much awaited final rule for implementation of the Medicare Shared Savings Program for providers and suppliers participating in Accountable Care Organizations (ACOs). The following are 20 notable aspects of the final rule: •1. While the proposed rule would have required all ACOs to…

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CMS Releases Final Rule for Accountable Care Organizations

Today, the Centers for Medicare and Medicaid Services (CMS) released its final rule for Medicare’s Accountable Care Organizations (ACO). The program is designed to encourage health care providers to coordinate care in order to achieve cost-savings and improve the quality of care for Medicare patients. Due to substantial criticism from…

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OIG Releases Unfavorable Advisory Opinion Regarding an Arrangement Between a Physician-Invested Entity and a Pathology Laboratory

On October 3, 2011, the Department of Health and Human Services Office of Inspector General (OIG) issued an unfavorable advisory opinion regarding a proposed arrangement under which physicians would invest in a company that would provide pathology laboratory management services to a third party. Under the proposed arrangement, a physician…

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US District Court Denies an Ambulance Services’ Request for Preliminary Injunction Against a Medicare PSC

On October 7, 2011, the United States District Court of New Jersey, made a ruling denying an ambulance services’ request for a preliminary injunction against a Medicare program safeguard contractor (PSC). National Ambulance Services, Inc. (“Nationwide”) sought a preliminary injunction to restrain SafeGuard Services, LLC (“Safeguard”) from continuing its pre-payment…

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CMS Sends ACO Final Rule to the Office of Management and Budget for Review

According to a breaking news article by HealthData Management, the Centers for Medicare and Medicaid Services (CMS) has sent a Shared Saving/Accountable Care Organizations final rule to the Office of Management and Budget (OMB) for review. A review by OMB is one of the last stages before a rule becomes…

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Recent RAC Updates (DCS Healthcare and CGI Federal)

DCS Healthcare, the RAC for Region A, posted four new issues to its CMS-approved issues list for providers in Maryland. Medical Necessity Review (MNR)- MDC 5 conditions of the circulatory system (medical) MS-DRGs: 286-293, 299-305, and 308- 316. Medicare pays for inpatient hospital services that are medically necessary for the…

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Recent RAC Updates (CGI Federal New Issues and CIGNA Government Services New Issues)

CGI Federal, the RAC for Region B, added two new issues to its CMS-approved issues list. In addition, two more issues were added to the CMS-approved issues list for DME suppliers who bill CIGNA Government Services. CGI Federal New Issues Leuprolide 3.75mg incorrect code reported (Region B). The purpose of…

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