Asha M. Natarajan

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The U.S. Governmental Accountability Office (GAO) has issued a new report to Congress identifying key issues facing the Medicaid program and urging greater federal oversight. The report comes at a time of significant transformation for the Medicaid program, which is currently celebrating its 50th year. Following its historic expansion as a result of the Affordable Care Act to provide health care coverage to approximately 70 million individuals nationwide, multiple bills are pending in Congress…
This is the sixth post in Health Care Law Today’s series on the final rule. This post addresses additional program requirements and beneficiary protections. The Medicare Shared Savings Program (“MSSP”) final rule published on June 4, 2015 finalized all proposed additional program requirements and beneficiary protections outlined in the December 2014 proposed rule. The specific additional public reporting obligations that ACOs must fulfill to participate in the MSSP that CMS finalized include:…
The recent release of a New York State Office of the State Comptroller audit report serves as an example of state Medicaid programs that may not be maximizing their collection of revenue from drug rebates for Medicaid managed care enrollees. This report indicated that the New York Medicaid program did not collect as much as $119.3 million in drug rebates due to managed care organizations’ (MCOs’) failure to resubmit nearly one million rejected encounter claims between…
This is the third post in Health Care Law Today’s series on the ACO proposed rule. Click here to read the first post and here to read the second post. Additional Program Requirements and Beneficiary Protections Under the Medicare Shared Savings Program (“MSSP”) ACO proposed rule, CMS has proposed additional program requirements, beneficiary protections and participation agreement procedures to enhance ACO transparency and improve patients’ ability to make informed health care decisions. Specifically, CMS has…
President Obama signed the “Improving Medicare Post-Acute Care Transformation Act of 2014” or the IMPACT Act of 2014 (the Act) on October 6, 2014. The new law is broadly focused on requiring all post-acute care providers to adopt standardized data protocols for patient assessment, quality of care and resource use data so as to allow for the exchange of such data.  However, one section of the Act singles out hospices for heightened scrutiny by federal regulators.…
New York-Presbyterian Hospital (NYP) will pay $3.3 million and Columbia University (CU) will pay $1.5 million to settle allegations that they failed to secure thousands of patients’ electronic protected health information (ePHI) held on their network. The monetary payments totaling $4,800,000 are the largest HIPAA settlement to date. In addition to the payment of this significant fine, NYP and CU have agreed to implement a substantial corrective action plan under the NYP Resolution Agreement and…
The New York State Office of the Medicaid Inspector General (OMIG) is the New York State (NYS) Medicaid program’s “watchdog” agency. (Last year they recovered in excess of $851 million from providers and others.) It is one of the most prominent state OMIG’s in the country, so providers in other states keep an eye on what the NYS OMIG does even if they do not operate in New York. The NYS OMIG issues a Work Plan each year…
As part of the Affordable Care Act “ACA”, Congress outlined the process for providers to return Medicare and Medicaid overpayments. In 2012, CMS proposed the 60-day Refund Rule, as it is commonly known, requiring Medicare providers and suppliers to report and return reimbursements made in error within 60 days of their identification.  While the proposed rule does not address Medicaid overpayments, CMS noted that it intended to address the process of collecting Medicaid overpayments at a…