Posts tagged proposed rule
Remote Therapeutic Monitoring in the 2022 MPFS: How CMS Can (and Should) Get it Right
Remote Therapeutic Monitoring in the 2022 MPFS: How CMS Can (and Should) Get it Right

This is our take on the approach CMS should follow in improving and finalizing the RTM codes and associated reimbursement that improve patient outcomes and lower the overall cost of care. It is based on our extensive work with remote patient monitoring and care management digital health companies along with the physician practices who use the existing care management codes – including Remote Patient Monitoring (“RPM”), Chronic Care Management, Principal Care Management, and Behavioral Health Integration.

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Remote MonitoringCarrie Nixon2022 Medicare Physician Fee Schedule, Remote Therapeutic Monitoring, remote patient monitoring, Remote Monitoring, virtual care, RPM, RTM, MPFS, 2022, proposed rule, proposed medicare physician fee schedule, medicare physician fee schedule, CMS
Proposed 2022 MPFS: Expansion in Audio-Only Telehealth, Permanent Remote “Direct Supervision”, and Remaining Opportunities for New Permanent Telehealth Codes
Proposed 2022 MPFS: Expansion in Audio-Only Telehealth, Permanent Remote “Direct Supervision”, and Remaining Opportunities for New Permanent Telehealth Codes

CMS didn’t propose to add any permanent telehealth codes, but did incrementally expand patient access to telehealth in other ways.

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Medicare Physician Fee ScheduleRebecca Gwiltproposed rule, telementalhealth, audio-only reimbursement, chronic pain management, rural health clinics, FQHCs, Opioid treatment programs, telebehavioral health, remote supervision, chronic pain
HHS Proposes New Safe Harbors Under the Anti-Kickback Statute and The Stark Law
HHS Proposes New Safe Harbors Under the Anti-Kickback Statute and The Stark Law

In a pair of proposed rules released by the Department of Health and Human Services (DHHS), Office of Inspector General (OIG) and the Centers for Medicare and Medicaid Services (CMS), the DHHS is looking to increase the utilization of value-based arrangements to drive health outcomes and ease the regulatory burdens associated with patient care coordination.  The proposed rules seek to change or add certain safe harbors or exceptions to the Anti-Kickback Statute (AKS), Physician Self-Referral prohibition (Stark Law), and the Civil Monetary Penalties (CMP) laws. 

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Corporate Healthcare LawTommy MillerHHS, Stark Law, CMP, OIG, dhhs, CMS, Anti-Kickback, proposed rule, Safe Harbor, AKS Safe Harbor