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Hello,
In this issue
CMS
releases new guidance for group practices enrolling in Medicare
The Centers
for Medicare & Medicaid Services recently released new guidance for
group practices interested in using the Internet-based Provider Enrollment,
Chain & Ownership System (PECOS) to enroll in the Medicare program.
Internet-based PECOS, launched last December, is available to individual
practitioners and organizations, such as group practices. If your
practice or practitioners last enrolled in Medicare after 2003, the
enrollment information should already be in the system, making it much
easier for any changes or updates to be made. If your practice or
practitioners enrolled in Medicare before 2003, you will have to enter
information as if completing a new application. However, the information
will be there for you the next time you need to update or change it.
Obtain a
copy of the guidance. Get
additional information on Internet-based PECOS from the CMS enrollment
Web-site and select “Internet-based PECOS” from the navigation box on the
left side of the page.
For
tips on navigating the Medicare enrollment process, as well as
information on the differences between the paper CMS-855 application and
Internet-based PECOS, download the Medicare
Provider Enrollment Toolkit created by the Medical Group
Management Association and the American Medical Association. The toolkit is
available exclusively to members of those organizations.
OIG
approves ASC joint venture between hospital and surgeons
The Office
of Inspector General (OIG) of the Department of Health and Human Services
issued an advisory opinion sanctioning a joint venture arrangement between
a group of orthopedic surgeons and a hospital to form an ambulatory surgery
center (ASC). The requestors of the opinion sought the OIGs input on
whether the proposed arrangement would violate the anti-kickback statute,
which prohibits giving or receiving any remuneration in exchange for the
referral of patients to receive items or services reimbursable under any
federal health care program.
The
agency has developed a number of safe harbors for arrangements that could
technically violate the prohibition but that contain enough safeguards that
they are unlikely to result in fraud or abuse. The proposed arrangement
does not meet the relevant safe harbor for ASC joint ventures between
hospitals and physicians for three reasons: 1) the hospital would be in a
position to make referrals to the ASC and the surgeon investors; 2) the
physicians would not hold their interests in the ASC directly but through a
limited liability company; and 3) the hospital and the surgeons could
potentially receive different returns on their investments. The OIG
analyzed the arrangement and the safeguards the parties had built into their
agreement. It determined that the risk of abuse would be low, and it would
therefore not impose sanctions on the parties involved.
As with
all advisory opinions, the analysis in this case is limited to the
requestors of the opinion and cannot be relied upon by other parties.
Read the
advisory
opinion.
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