Federal Government scrutiny over healthcare providers’ use of CPT Code Modifier 25 is not new, but we are seeing an uptick in enforcement. The U.S. Department of Health and Human Services, Office of Inspector General (“OIG”), has targeted the use of Modifier 25 in its yearly work plans. The OIG’s yearly work plans outline the [...]
On March 20, 2018, Governor Rick Scott signed Senate Bill 622 into law, which made significant changes relevant to clinical laboratories governed by the Agency for Health Care Administration (“AHCA”). This law became effective July 1, 2018. Previously, facilities performing any “non-waived” clinical laboratory testing (i.e., testing using a microscope) had to obtain a state [...]
On March 24, 2018, Governor Rick Scott signed House Bill 37 into law specifying that direct primary care agreements are not insurance. Under direct primary care agreements, primary care providers enter into private contracts with their patients and charge them monthly fees in advance of providing services, with no third-party billing. This law is effective [...]
On March 20, 2018, Governor Rick Scott signed Senate Bill 622 into law, which made significant changes relevant to various health care facilities governed by the Agency for Health Care Administration (“AHCA”). This law is effective July 1, 2018. One change is with regards to the health care clinic certificate of exemption. A health care [...]
You have been running your business for years, perhaps even decades, and the time has come for you to transition the business to someone else. The buyer of your business could take a variety of forms, such as a key employee, family member, a competitor in your particular industry or a private equity group. Regardless [...]
The Department of Health and Human Services ("HHS") recently issued guidance regarding the practice of a Business Associate cutting off a Covered Entity's access to Protected Health Information ("PHI"). This may occur when a healthcare provider refuses to pay its electronic medical records (“EMR”) vendor or when the provider decides to switch vendors. The EMR vendor may [...]
Business Associate Tracking Form Click to download
In May 2009, the Department of Health and Human Services (HHS) and Department of Justice (DOJ) created the Health Care Fraud Prevention and Enforcement Action Team (HEAT). The HEAT initiative is a multi-agency team of federal, state, and local investigators that use data analysis techniques to fight health care fraud, such as data mining, predictive [...]
Section 1557 of the Affordable Care Act prohibits discrimination on the basis of race, color, national origin, sex, disability and age by any health care program or activity which receives federal funding from the Department of Health and Human Services. It is the first Federal civil rights law to broadly prohibit sex...
Section 1557 of the Affordable Care Act prohibits discrimination on the basis of race, color, national origin, sex, disability and age by any health care program or activity which receives federal funding from the Department of Health and Human Services. It is the first Federal civil rights law to broadly prohibit sex discrimination in health [...]
Most business owners can agree on one thing: the importance of a business plan. Most business owners, however, often overlook the importance of incorporating trademark protection into a business plan. Whether your company is a start-up or a business that has been in existence for years, incorporating adequate trademark protection into your business plan can [...]
During its past session the Florida legislature passed several bills that were signed into law that change the ability of Advanced Registered Nurse Practitioners (“ARNPs”) and Physician Assistants (“PAs”) to prescribe Schedule II, III and IV controlled substances. It is important to note that while the legislation is effective July 1, 2016, the authority to [...]
