OIG Report on Improper ENT Billing

The Department of Health and Human Services (“HHS”) Office of the Inspector General (“OIG”) recently released a report presenting the results of an extensive medical record review conducted in 2006 regarding payments made to nursing facilities for Medicare Part B enteral nutrition therapy (“ENT”) claims for non-Part A patients. The study found that 21 percent of the claims were inappropriate or inadequately documented, resulting in an estimated $39 million in Part B payments that the government should not have paid. Although in the 2010 Work Plan OIG already declared its intent to focus on review of nursing homes’ Part B ENT billing, this report may result in increased scrutiny of providers’ claims and documentation.

DGS Health Law Blog Recognized as Top Reference for HIPAA / HITECH

We are pleased to announce that the DGS Health Law Blog has been recognized by HealthInsuranceQuotes.org as one of 47 top-rated and top-referenced health blogs for understanding HIPAA issues.  We are delighted that people are finding our blog useful and we encourage you to contact any of our attorneys if you have further questions about HIPAA or HITECH matters.

Tags:

Grandfathered Health Plans: New Interim Regulations

Last week the United States Departments of Treasury, Labor and Health and Human Services issued Interim Final Rules providing guidance on “grandfathered health plans” under health care reform. The Patient Protection and Affordable Care Act (“PPACA”) set different standards for grandfathered health plans than for those plans not grandfathered. According to these regulations, health plans that existed on March 23, 2010 will be significantly restricted in the changes they can make to copayments, deductibles and benefits covered if the plans want to maintain grandfathered status and avoid the new requirements of PPACA.

Most plans will fail to qualify for grandfathered status over the next three years, according to the Departments’ analysis in the Interim Final Rules. The greatest impact will be on small employers with between 3 and 99 employees. The Departments estimate that between 49% and 80% of small employer plans will relinquish their grandfathered status by 2013. In addition, the Departments estimate that between 34% and 64% of large employer plans will relinquish their grandfathered status by 2013.

Continue Reading...