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Wisconsin Health Law Posts
- The Physician Board Member – Meeting Your Responsibilities as a Director
- Concierge Medicine Agreements – Five Key Contract Clauses for Medical Practices
- Telehealth Membership Platforms: A Provider Compliance Guide
- Medicare Opt-Out – A Make-or-Break Decision for Concierge Physicians
- Hybrid Concierge Models – Why Popularity Comes With Compliance Risk
- Cash-Based Clinics – A Regulatory Landscape More Complex Than It Appears
- State Spotlight: Wisconsin, Illinois, and Michigan — Three Distinct Regulatory Environments
- Understanding HIPAA and Its Interaction with State and Federal Confidentiality Laws
- Concierge Medicine Legal Guide: Key Compliance and Business Issues for Physicians
- Direct Primary Care (DPC) vs. Concierge Medicine: A Regulatory Comparison
- Physician Autonomy in the Value-Based Care Era: Legal and Operational Priorities for Health Care Providers
- Telehealth and Concierge Medicine – A Strong Fit with Complex Rules
- Preparing for Certification Surveys at Ambulatory Surgery Centers
- Podcast – ASC 2030: The New Playbook
- Podcast – ASC Life Safety Code Decoded
- Podcast – ASC Survey Ready Now
- Podcast – QAPI: Build It Right
- Podcast – Closing Infection Control Gaps
- Podcast – ASC Governance Accountability
- ACO Primary Care Exclusivity Requirement – Not As Broad As Some Believe
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Tag Archives: Cash-Based Medical Practices
Medicare Opt-Out – A Make-or-Break Decision for Concierge Physicians
For physicians moving into concierge, direct-pay, or cash-based practice models, opting out of Medicare is a consequential compliance decision—not merely an administrative formality. A properly executed Medicare opt-out changes how the physician may treat and bill Medicare beneficiaries, how private … Continue reading
Posted in Consierge & Cash-Based Practices, Medicare and Medicaid, Medicare and Medicaid Reimbursement, Physician Issues, Reimbursement & Payment Practices
Tagged Cash-Based Medical Practices, Medicare Opt-Out, opt-out rules, opting out of medicare
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THE OIG ADVISORY OPINION PATHWAY FOR CONIERGE AND CASH-BASED PRACTICES
For arrangements that are novel, involve significant financial investment, or present a unique structural profile without a clear safe harbor fit, the OIG Advisory Opinion process provides a mechanism for obtaining binding regulatory guidance. Under 42 C.F.R. § 1008.38, a … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Physician Issues, Reimbursement & Payment Practices, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, concierge practice, direct primary care, Medicare Reimbursement, wisconsin health lawyer
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SAFE HARBORS MOST RELEVANT TO CONCIERGE AND DPC PRACTICES
The regulatory safe harbors at 42 C.F.R. § 1001.952 provide the primary mechanism for structuring arrangements that would otherwise implicate the AKS. An arrangement that satisfies every element of an applicable safe harbor is protected from AKS prosecution. An arrangement … Continue reading
Posted in Compliance Issues, Consierge & Cash-Based Practices, Fraud and Abuse, Stark Law and Anti-Kickback Issues, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, wisconsin health lawyer
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WHY CONCIERGE AND DPC PRACTICES ARE NOT AUTOMATICALLY EXEMPT
The AKS exposure of a concierge or cash-based practice depends heavily on its specific structure and business relationships. The analysis differs materially across three broad categories of practice. A. Pure Cash / DPC Practice — No Federal Program Participation A … Continue reading
Posted in Consierge & Cash-Based Practices, Fraud and Abuse, Medicare and Medicaid, Stark Law and Anti-Kickback Issues, Telemedicine, Wisconsin Health Laws
Tagged anti-kickback statute, Cash-Based Medical Practices, Concierge Medicine, Hybrid Concierge Practice, Medicare Opt-Out
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