OIG Issues Advisory Opinion
The Department of Health and Human Services Office of Inspector General (“OIG”) published Advisory Opinion 24-09. In this Opinion, the OIG responds to a request regarding a proposal to bill patients’ insurance plans and waive any patient cost-sharing amounts for treatment-in-place emergency medical services without an associated ambulance transport. The OIG advised that, although the proposed arrangement, if undertaken, would generate prohibited remuneration under the Federal anti-Kickback statute, if the requisite intent was present, and the Beneficiary Inducement CMP, the OIG would not impose administrative sanctions on the requestor.
CMS Finalizes Rule Establishing Mandatory Transplant Model
The Centers for Medicare & Medicaid Services published a final rule establishing the Increasing Organ Transplant Access Model. Transplant hospitals within certain Donation Service Areas will be required to participate in the six-year model. Among other things, the model will provide incentives to transplant hospitals to perform more transplants and disincentives to those hospitals that perform fewer transplants in what CMS refers to as a “two-sided risk.”
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