Florida Court finds PPACA to be unconstitutional

In a 78 page opinion issued today by the U.S. District Court in Florida,the Patient Protection and Affordable Care Act was found to be unconstitutional.  The lawsuit was originally filed by the Florida State Attorney General immediately after PPACA became law, and 25 other state Governors or Attorneys General later joined as plaintiffs.  

Judge Vinson, who ruled in the case, made it clear at the outset that this decision was not about health care or the health care system, but was really a case about federalism and the limitations on the powers of the federal government under the Constitution.  The  opinion contains a detailed review of the history of the Supreme Court's interpretations of the Commerce Clause of the Constitution, and then applies that foundation to the question of whether or not the statute's mandate for individuals to purchase health insurance is a permissible exercise of Congressional power.  After lengthy analysis, Judge Vinson determined that it was beyond the scope of the commerce clause, as it was an attempt to regulate what was effectively individual "inactivity", that is to say a decision by an individual not to participate in commerce, rather than an "activity" related to interstate commerce. The Court wisely recognized that ultimately this is an issue that the Supreme Court must decide.   The discussion of this question is, for someone with an interest in politics or the law, really quite fascinating.

  

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Government Intensifies Health Care Fraud Enforcement Efforts

Health care fraud and abuse enforcement is always on our minds and our clients' minds, but yesterday HHS and DOJ gave health care providers even more to consider when evaluating their own fraud and abuse compliance efforts.

HHS and DOJ announced the highest annual recovery amount ever from health care providers as a result of the federal government's fraud and abuse enforcement efforts.  According to the annual Health Care Fraud and Abuse Control Program ("HCFAC") report released yesterday, the government’s health care fraud prevention and enforcement efforts recovered a staggering $4 billion from health care providers in fiscal year 2010.

This year's $4 billion recovery amount is up 50% from 2009.  To further put this $4 billion into context,  the HCFAC has returned $18 billion total to the Medicare Trust Fund since its inception in 1997.  This increased recovery is due, at least in part, to the recently employed enforcement teams such as the Health Care Fraud Prevention & Enforcement Action Team ("HEAT") and the Medicare Fraud Strike Force.  In addition to these criminal enforcement recoveries, the government also obtained more than $2.5 billion in civil health care matters brought under the False Claims Act, which is the largest in the history of the DOJ. 

HHS also announced yesterday new rules authorized by PPACA (or the Affordable Care Act) that will further intensify the government's efforts to fight fraud, waste and abuse in Medicare and Medicaid.  Not only does PPACA provide an additional $350 million for HCFAC activities, but the rules include new provider screening and enfocement measures and gives the government the authority to suspend payments to providers when credible allegations of fraud are being investigated.  These provisions--particularly the suspension of payment during investigations--are likely to have a significant impact on providers in the coming years.  These regulations take effect March 25, 2011.

Although these recovery amounts seem high compared to previous years, health care providers should expect that recoveries may increase even further in coming years with the government's sharpened focus on health care fraud and abuse.

DGS Health Law Blog Named a Top 50 Healthcare Industry Blog

If you are a blogger, you know that maintaining rich, informative, relevant and timely blog content is a labor of love. That's why I'm so pleased to see that the DGS Health Law Blog has been named as one of the Top 50 Healthcare Industry Blogs by Health Nation. You can click here to see the full Health Nation article. Congratulations John, Barbara, Wally, Erin & Lisa!

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