OIG issues Special Fraud Alert on business arrangements with physician-owned entities *

USA - April 12 2013
On March 26, the HHS Office of Inspector General (OIG) issued a Special Fraud Alert (Fraud Alert) reiterating its long-standing concern that the…

Co-authors: Elizabeth M. Mills, Richard J Zall, Ellen H Moskowitz, Edward S Kornreich, Malcolm J Harkins, III.

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HHS issues HIPAA/HITECH Omnibus Final Rule ushering in significant changes to existing regulations *

USA - January 29 2013
"Sweeping changes" is how Leon Rodriquez, of the Department of Health and Human Services Office of Civil Rights (OCR), characterized the effect of…

Co-authors: Richard J Zall, Kristen J Mathews, Ellen H Moskowitz, Ryan P Blaney, Edward S Kornreich.

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A warning regarding impermissible arrangements between anesthesiologists and ASCs – but a warning to whom? *

USA - July 10 2012
On June 1, 2012, the U.S. Department of Health and Human Services, Office of Inspector General ("OIG") issued Advisory Opinion 12-06 (the "Opinion") concerning two proposals by an anesthesia services provider (the "Requestor") for restructuring its relationship with several ambulatory surgery centers ("ASCs").

Co-authors: Brian J Kinsella, Edward S Kornreich.

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Small practice subject to $100,000 payment to resolve alleged HIPAA violations *

USA - April 30 2012
Phoenix Cardiac Surgery, P.C. is a professional practice owned by two physicians in Phoenix, AZ.

Co-authors: Richard J Zall, Robyn Sterling.

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OIG approves "per-click" payments for transmission of referral information as part of integrated electronic health record and physician office support service *

USA - December 9 2011
On November 30, 2011, the U.S. Department of Health and Human Services, Office of Inspector General, issued a favorable Advisory Opinion relating to a set of services that includes the preparation and transmission of referral orders between health care providers in which part of the service fees, including fees paid by referral recipients, are determined on a "click-fee" basis.

Co-authors: Elizabeth M. Mills, Richard J Zall.

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