Lisa A. Estrada

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Recent audits by the Department of Health and Human Services Office of Inspector General (“OIG”) conclude that state survey agencies in a number of states and a leading national accrediting agency serving the home health and hospice industry failed to identify a significant number of deficiencies related to worker qualifications. Based on these findings, OIG concluded that reliance on these surveyors by the Center for Medicare and Medicaid Services (“CMS”) could be inadequate to ensure…
It appears that the Office of Inspector General (“OIG”) now has physicians squarely in the crosshairs of one of its most powerful enforcement tools: the Anti-Kickback Statute (“AKS”). The AKS is a criminal statute with stiff penalties. It prohibits the offer or payment of anything of value with the intent to induce the referral of federal health care program business, including specifically Medicare and Medicaid. Physicians, in particular, should be aware that the AKS also…
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.…
On August 4, 2014, the Centers for Medicare & Medicaid Services (CMS) issued a final rule updating the hospice wage index and payment rate for Fiscal Year (FY) 2015 and adopting a number of payment reforms addressing concerns about program integrity, beneficiary protection, and quality (Final Rule). CMS also issued an accompanying Fact Sheet which summarizes the significant provisions. The Final Rule will be published in the Federal Register on August 22, 2014 with an…