By Jennifer Jones Thomas

On September 10, 2019, the Centers for Medicare and Medicaid Services (“CMS”) published a Final Rule in the Federal Register which will require Medicare, Medicaid, and Children’s Health Insurance Program (“CHIP”) providers and suppliers to disclose current and previous affiliations with other providers and suppliers who CMS identifies as posing an

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By Tyler Moore Kostal

Historically, the Benefits Coordination and Recovery Center (“BCRC”) arm of the Centers for Medicare & Medicaid Services (“CMS”) collected Medicare’s conditional payments.  While the BCRC continues to address Medicare’s reimbursement rights with Medicare beneficiaries, in late 2015 the CMS’s Commercial Repayment Center (“CRC”) took over responsibility for seeking reimbursement directly from

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By Deborah J. Juneau

The OIG issued Advisory Opinion 15-3 to address an arrangement proposed by a licensed offeror of Medicare Supplemental Health Insurance (“Medigap”) policies (the “Requestor”), in which the Requestor would indirectly contract with a preferred hospital organization (“PPO”) having contracts with a national network of hospitals (the “Network Hospitals”) for discounts on

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By Lyn S. Savoie

The latest OIG Advisory Opinion, issued February 9, 2015, addresses the issue of sharing federal health care program payments with an excluded practitioner.   While federal statutes prohibit payment by any federal health care program, including Medicare or Medicaid, for items or services furnished by an excluded person or furnished at the