Category Archives: Uncategorized

New Memorandum On Telehealth In Mental Health and Substance Abuse Programs

By John Fisher, JD, CHC, CCEP Wisconsin Updates Telehealth Guidance for Mental Health and Substance Abuse Programs Client Alert: August 11, 2015 What Changed? The Wisconsin Division of Quality Assurance (DQA) has issued updated guidance on the use of telehealth … Continue reading

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Concierge Medicine Article Series | The Anti-kickback Statute in Concierge and Cash-based Medical Practices

By John Fisher, JD, CHC, CCEP The Concierge and Cash-Based Medical Practice Article Series explores the evolving landscape of healthcare delivery models that prioritize patient-centered care, transparency, and direct financial relationships between patients and providers. Through this series, readers will … Continue reading

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Confidentiality of Substance Use Disorder Patient Records

By Fisher, JD, CHC, CCEP 2018 SAMHSA Final Rule: Clarifying Part 2 Confidentiality Requirements On January 3, 2018, the Substance Abuse and Mental Health Services Administration (SAMHSA) published final regulations updating 42 CFR Part 2, the federal confidentiality rules governing … Continue reading

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Physician Orders – Definition and Reimbursement Implications

By Fisher, JD, CHC, CCEP Physician Order Compliance: Definitions, Documentation, and Medicare Payment Risk Physician order compliance is a practical issue for health care providers, billing teams, and compliance professionals because physician orders help direct patient care, support medical necessity, … Continue reading

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The Impact of a Physician’s Ethical Obligations on Concierge Program Structure

As with other types of practice arrangements, concierge medicine arrangement require attention to the ethical implications. Physicians who enter these arrangements will want to assure that the structure and operation of the concierge practice does not violate any ethical principles. … Continue reading

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Applying Section 1557 Discrimination Rules to Employer Sponsored Health Plans

By Fisher, JD, CHC, CCEP Section 1557 Final Rule: Implications for Covered Entities and Employer-Sponsored Health Plans April 2024 Executive Summary The U.S. Department of Health and Human Services (“HHS”) finalized regulations implementing Section 1557 of the Affordable Care Act … Continue reading

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DOJ Skilled Nursing Facility Settlement Involving Rehab – Highest Ever

By Fisher, JD, CHC, CCEP Skilled Nursing Facility False Claims Act Settlement Signals Continued Scrutiny of Therapy Billing Client Alert | Health Care Enforcement and Compliance Skilled nursing facility operators should continue to pay close attention to how rehabilitation therapy … Continue reading

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When may a Referral be Mandated for Employed Physicians under the Stark Law?

By Fisher, JD, CHC, CCEP    When Can an Employer Require Referrals from Employed Physicians Under the Stark Law? The Stark Law, also known as the Physician Self-Referral Law, generally prohibits physicians from referring Medicare or Medicaid patients for designated … Continue reading

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Unnecessary Inpatient Admissions Results in Hospital DOJ Settlement

Hospital Inpatient Admission Fraud: False Claims Act Risks for Unnecessary Hospital Admissions Quick Answer: What Is Hospital Inpatient Admission Fraud? Hospital inpatient admission fraud occurs when a hospital allegedly bills a federal health care program for inpatient care that was … Continue reading

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Whistleblower Settlements Increase Compliance Risk for Providers

By Fisher, JD, CHC, CCEP Recent Fraud Settlements Highlight Whistleblower and Compliance Risks for Health Care Providers Health care compliance officers and counsel often review fraud settlements to identify the enforcement priorities receiving government attention. Although settlement announcements do not … Continue reading

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