COMPLIANCE PERSPECTIVES

PAMA Reimbursement: CMS Tells Labs How to Secure ADLT Status for New Tests

Although the 2018 market-based Clinical Laboratory Fee Schedule (CLFS) is officially in effect, implementation of the new PAMA Part B payment rules for lab tests remains a work in progress. On March … [Read more...]

LEGISLATION

Brief Your CEO: New Penalties Double the Dollar Value of Protecting Your Lab from Liability

You may not realize this, but Congress has just doubled the dollar value of what you do as a compliance manager to keep your lab out of federal health care fraud hot water. How? By significantly … [Read more...]

ANTI-KICKBACK

You Make the Call: Self-Disclosing Non-Compliant Arrangements with Large Physician Groups

SITUATION Fictional Med (FM), a large physician-owned clinic, is one of your lab's biggest customers. So your heart sinks when during an internal compliance audit, you discover that your lab has been … [Read more...]

LEGISLATION

PAMA-Geddon: Lab Industry Takes CMS to Court

The nearly three-year struggle between HHS and the lab industry over PAMA has entered a new phase. On December 11, the American Clinical Laboratory Association (ACLA) filed a lawsuit asking the U.S. … [Read more...]

COMPLIANCE PERSPECTIVES

CMS Finalizes Controversial PAMA Fee Schedule

It's official. Brushing aside fierce lab industry opposition, CMS has decided to go forward with its PAMA Clinical Laboratory Fee Schedule (CLFS) in 2018. The Flawed Fee Schedule The intent of the … [Read more...]

COMPLIANCE PERSPECTIVES

PAMA-Geddon: Proposed 2018 Lab Pay Rates Are a Bloodbath

There will be no delay; and And hospital labs will remain excluded from "applicable laboratories" on which supposed market rate payments for lab tests will be based. Those were the first … [Read more...]

COMPLIANCE

You Make the Call: Is Replacing Spoiled Products for Free an Anti-Kickback Violation?

The following scenario comes right out of an August 25, 2017 OIG Advisory Opinion. See if you can guess how the OIG ruled. SITUATION A pharmaceutical company manufactures biologics prone to spoilage … [Read more...]

FOCUS ON

Kickbacks: Does OIG Green Light of Free Product Replacements Open Door for Lab Freebies?

The OIG's aversion to offering freebies of any kind to referral sources is longstanding and well known. So the Aug. 25, 2017 Advisory Opinion clearing the way for a provider to replace spoiled … [Read more...]

NEWS

Compliance Planning: OIG Switches from Semi-Annual to Monthly Work Plan Updates

When it comes to running a laboratory compliance plan, the semi-annual OIG Work Plan can be a big help to because it enables you to keep track of new enforcement initiatives and respond to emerging … [Read more...]

COMPLIANCE PERSPECTIVE

10 Traps to Avoid When Investigating Potential Whistleblower Complaints

If one of your employees comes forward to report a billing, coding, reimbursement or other potential violation, the liability of your lab will turn on two critical questions: Is the employee … [Read more...]


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