When closing a New Jersey pharmacy, to protect patient access to medication and records and minimize the disruption to continuity of care, certain steps should be followed.
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Consistently over the years the Office of Inspector General (OIG) has targeted chiropractic services for audits. In fact, chiropractic services appear annually on the OIG’s workplan agenda. In September 2015, the OIG issued a report recommending that the Centers for Medicare & Medicaid Services’ (CMS) establish better controls and measures to prevent questionable payments, collect overpayments based on inappropriately paid claims and ensure that claims are paid only for Medicare-covered diagnoses. The Office of Inspector General (OIG) recently audited New Jersey’s personal care program and found certain deficiencies as a result of noncompliance with Federal and State requirements by some personal care agencies. Based on the audit result, the OIG asked the State to return $32,236,308 in Federal Medicaid reimbursement for personal care services that the OIG claimed did not meet Federal and State requirements. In a series of recent reports, the Office of Inspector General (OIG) noted a number of deficiencies and made a number of recommendations to improve and strengthen oversight of the HIPAA Privacy Standards and reduce the amount of inappropriate transportation billing. Recent guidance from the New York State Office of the Professions (OP) suggests that the agency did not entirely reject Internet coupons or vouchers that many refer to as “Groupons.” The OP did, however, affirm concerns previously expressed here that offering coupons for medical services requires careful consideration. Recent changes to the New York State Medicaid Program affect vaccine administration for pharmacies, claiming process for nurse practitioners, documentation requirements for transportation providers, and prior authorization for physical and occupational therapists. We summarize these changes. The New Jersey’s Prescription Monitoring Program (NJPMP), aimed at halting the abuse and diversion of prescription drugs, was substantially updated recently to impose new requirements on prescribers of Schedule II drugs and, separately, to stiffen penalties for pharmacists failing to timely report information about dispensing of the controlled dangerous substance (“CDS”). The Centers for Medicare & Medicaid Services (CMS) recently announced another six month extension of moratoria on new home health agencies, home health agency sub-units, and Part B ground ambulance suppliers in certain locations throughout the country. A new law impacting New York out-of-network providers, called the Emergency Services and Surprise Bill, went into effect on March 31, 2015, that will require providers to update their operations if they do not already comply with the legal requirements. On March 13, 2015, Gov. Cuomo signed an amendment extending by one year, until March 27, 2016, the implementation date for the mandatory electronic prescribing. Deniza Gertsberg, Esq. will be speaking during the upcoming NJSBA Health Law Section program on “Fundamentals of Medicare Provider Enrollment/Revalidation”. The program focuses on the steps in the Medicare enrollment/revalidation process and practical tips for successfully completing an enrollment/ revalidation, whether the attorney is submitting the 855 paper forms or using the Provider Enrollment Chain The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) made changes to the physician opt-out affidavit requirements. In a welcomed move, the Centers for Medicare & Medicaid Services (CMS) and American Medical Association (AMA) announced elimination of certain sanctions and penalties during ICD-10 transition and the availability of additional resources to help physicians get ready for ICD-10. The Centers for Medicare & Medicaid Services (CMS) published full year of 2014 financial data about transfers of value by drug and medical device makers to health care providers. The data includes information about 11.4 million financial transactions attributed to over 600,000 physicians and more than 1,100 teaching hospitals, totaling $6.49 billion. In a recent advisory opinion, the Office of Inspector General (OIG) nixed a proposed arrangement whereby a multi-regional laboratory (Lab) sought to provide free services to out-of-network patients in exchange for exclusivity in referrals from the physicians. Mandatory Electronic Prescribing Effective in NY. While the mandatory electronic prescribing was extended by Gov. Cuomo until March 27, 2016, e-prescribing for controlled and non-controlled substances is already available in New York for those meeting the regulatory requirements. Since 2011, NYS Medicaid Electronic Health Records Incentive Program has paid over $660 million in incentive funds “Physicians who enter into compensation arrangements such as medical directorships must ensure that those arrangements reflect fair market value for bona fide services the physicians actually provide,” warns the new fraud alert published by the Office of Inspector General (OIG). The Office of the Civil Rights (OCR) within the US Department of Health and Human Services recebtly settled a HIPAA violation case with a single location compounding pharmacy in Denver, Colorado. This is yet another HIPAA settlement underscoring the importance of properly implementing and maintaining a compliance plan. New York State Medicaid has a new vendor to implement the new Medicaid Management Information System (MMIS) that will eventually replace the current vendor (eMedNY). The new vendor, Xerox State Healthcare LLC, won a five year contract with the State. Implementation of the new system will occur in two phases over an eighteen month period. With labels such as “concierge medicine,” “VIP medicine,” “boutique medicine,” “exclusive practice,” “premium practices,” or “platinum medicine,” direct patient-doctor contractual arrangements have received their share of negative attention from the press as well as certain lawmakers since their inception in 1996. Perceived as medicine for the rich, some academics and ethicists worry that such “elitist” practices may cause access to care problems and would further “exacerbate the already tiered healthcare system, accelerate the fragmentation of insurance risk pools through cherry picking of the healthier patients, and promote the nonmedical services and amenities.” |
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