Practice Area	Title	Date
Health Law Regulatory Compliance	Supervision of Hospital Outpatient Therapeutic Services: CMS's Final Answer? The Center for Medicare and Medicaid Services ("CMS") recently published its 2010 Outpatient Prospective Payment System Final Rule ("Final Rule"). As part of its Final Rule, CMS changed and clarified the direct supervision requirements for hospital outpatient therapeutic services and procedures. The result of these changes is a relaxation of the direct supervision requirements for outpatient therapeutic services and procedures and added flexibility. Nevertheless, the Final Rule still presents challenges for hospitals in meeting the supervision standard.	11/16/09
Health Law Regulatory Compliance	OIG Publishes FY 2010 Work Plan The Office of Inspector General (the "OIG") has released its Fiscal Year 2010 Work Plan (the "2010 Plan"). The 2010 Plan describes the OIG's new and ongoing projects for the 2010 Fiscal Year to carry out its mission of, in part, ensuring the integrity of the Medicare and Medicaid programs. Many of the projects include audits and evaluations of the Center for Medicare and Medicaid Services ("CMS") and provider claims. The 2010 Plan generally addresses areas the OIG believes are prone to abuse or other error. Providers can review the 2010 Plan to develop compliance activities for the upcoming year.	10/12/09
Health Law Patient Care Issues and Risk Management Regulatory Compliance	Who's Supervising Who?: CMS's Newest Take On Supervision Of Incident To Outpatient Therapeutic Services Quality concerns, patient demands and physician staffing all contribute to providers' focus on supervision of mid-level providers (MLPs). Regarding services provided as incident to outpatient therapeutic services, the Center for Medicare and Medicaid Services (CMS) added to the confusion by issuing a "clarification" in the CY 2009 Outpatient Prospective Payment System (OPPS) Rule that tightened supervision requirements for on-campus and in-hospital outpatient departments. Since then, however, CMS has attempted to make this "clarification" more clear with the issuance of its proposed CY 2010 OPPS Rule. This article discusses CMS's proposed rule, with a specific focus on the proposed revisions to the supervision requirements for incident to outpatient therapeutic services.	07/08/09
Health Law Regulatory Compliance	Quality and Compliance: CMS Attempts To Add To Its Quality-Based Initiatives With the recent election and changes in administration, health care reform continues to be a hot topic. President-Elect Obama has promised to issue an economic recovery blueprint this week, with approximately one-fifth of the package reportedly slotted toward health care. Given this amount of financing, health care reform is a key issue. Senator Max Baucus issued a White Paper last month that sets out reform goals, many of which may be included as part of President-Elect Obama's final health care plan.	12/23/08