In a newly proposed rule the Office of the Inspector General (“OIG”) is proposing to exclude from the discount safe harbor certain types of remuneration offered by drug manufacturers to Part D plan sponsors and Medicaid MCOs that may pose a risk to the Federal health care programs and beneficiaries. The OIG is also proposing to add two new safe harbors. The first would protect certain manufacturer point-of-sale reductions, and the second would protect certain fixed service fees that manufactures pay to pharmacy benefits managers for services rendered to the manufacturer that meet specific criteria.
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The New Jersey Board of Dentistry (Board) recently expanded the scope of practice of licensed dental hygienists, limited registered dental assistants in orthodontics and registered dental assistants. Effected providers should become familiar with these expanded parameters. The New Jersey Board of Pharmacy and the New Jersey Board of Medical Examiners recently adopted new regulations and amended existing ones that effect the way providers practice. The changes concern pediatric immunizations performed by pharmacists and the administration of subcutaneous and intramuscular injections and venipunctures by certified medical assistants. We briefly summarize these recent changes below. The Centers for Medicare & Medicaid Services (CMS) recently published a proposed rule that, if codified, would bring about sweepings revisions to many Medicare payment policies under the physician fee schedule. Among many other changes CMS is proposing to simplify the documentation requirement for evaluation and management (E/M) code levels 2 through 5 but also proposes a flat fee for those levels of services. These and certain other proposed policy changes are briefly summarized below. New sweeping regulations went into effect on July 1, 2017 for dental anesthesia services in New York. The regulations, among other things, would require dentists to have additional and specific continued education courses, meet specific practice requirements and maintain more exacting records than previously required. The regulations will also impose more stringent requirements on dentists providing dental sedation to patients 12 years old and younger. We provide a summary of the new requirements in the article that follows. New York State Office of the Medicaid Inspector General (OMIG) annual 2018-2019 Work Plan highlights three areas of concern for the agency: (1) provider compliance; (2) identifying and addressing fraud, waste and abuse in the program; and (3) improving methods of detecting fraudulent activities. Recent analysis by the Comprehensive Error Rate Testing (CERT) initiative of physical therapy claims revealed that insufficient documentation contributed to improper payments issued to providers. New Jersey’s Division of Consumer Affairs is proposing to amend the Prescription Monitoring Program (PMP) to require pharmacies to electronically transmit information about prescriptions filled for gabapentin. The New Jersey Division of Consumer Affairs (“Division”) recently proposed amendments and a new rule to implement a 2014 law concerning health care service firms. The Bureau of Compliance (BOC) within the New York State Office of the Medicaid Inspector General (OMIG) recently performed an assessment of providers’ compliance programs. The results indicate that providers sometimes fail in relatively less complicated and readily addressable ways. Several of New Jersey’s professional licensing Boards recently adopted new controlled dangerous substance prescription requirements. Prescribers should be aware of the changes to avoid running afoul of the new regulations. In recognition of limitation of certain electronic prescribing software the NYS Health Commissioner approved a new blanket waiver for electronic prescribing requirements. The Centers for Medicare & Medicaid Services (CMS) has once again issued guidance reminding providers that federal law bars Medicare providers from billing a Qualified Medicare Beneficiaries (QMB) under any circumstances. The New York State Office of the Medicaid Inspector General (OMIG or agency) has recently issued its 2017-2018 Workplan. The Workplan identifies key areas of OMIG’s focus impacting health care providers and suppliers. Providers, suppliers and their billing staff need to be aware of the following recent changes to the Medicare program. The Office of Inspector General (OIG) recently published a final rule that implements OIG’s expanded statutory exclusion authority. The final rule included a number of provisions that impact providers and suppliers. Scope of practice matters and New Jersey dentists who fail to comply with the requirements for administering injectable pharmacologics such as Botox or Restylane may be subject to discipline. A recent report from the New Jersey Office of the State Comptroller indicates an expansion of the efforts of its Medicaid Fraud Division (MFD) to investigate fraud, waste and abuse in the New Jersey Medicaid Program. The report also highlights MFD’s expanded effort to exclude providers from the Medicaid Program. Failure by a covered entity to timely report a breach of protected health information (PHI) resulted in the first of its kind settlement in the amount of $475,000. New York State is working to expand the State’s medical marijuana program. |
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