Author: Neal N. Peterson

Neal N. Peterson

Neal regularly advises clients regarding compliance with laws specific to the health industry, such as state licensure requirements and corporate practice of medicine statutes and regulations. Neal's experience includes representing clients who are both payers and providers of health care, such as health insurers, HMOs, management services organizations, integrated delivery systems, accountable care organizations, hospitals, multi-specialty physician groups, pharmacies, nursing homes and assisted living facilities.

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CMS To Expand Use of TPE Audits Nationwide by End of 2017

Neal N. Peterson

Perhaps lost amid the healthcare news coverage of competing proposals regarding “Medicare for All” and the repeal of Obamacare, the Centers for Medicare & Medicaid Services (“CMS”) last month announced the expansion of its Targeted Probe and Educate (“TPE”) claims review program to the entire country by the end of the year. CMS’s announcement can...

CMS Gives Clinical Labs Reporting Deadline Extension

Neal N. Peterson

Clinical laboratories have until May 30, 2017 to make required reports to the Centers for Medicare & Medicaid Services (“CMS”) regarding payment rates paid by private payors for certain diagnostic tests and the volume of such tests furnished for such payors, according to a CMS announcement on March 30, 2017. Last year CMS issued a...

OIG Interprets and Incorporates Statutory Exceptions to CMP Law

Neal N. Peterson

As of January 6, 2017, final rules published by the United States Department of Health and Human Services Office of the Inspector General (the “OIG”) implementing certain exceptions to the Civil Monetary Penalty law (“CMP”) took effect. The CMP rules were published alongside final rules regarding safe harbors to the federal Anti-Kickback Statute (“AKS”), about...

OIG Creates New AKS Safe Harbors, Codifies Others

Neal N. Peterson

On January 6, 2017, two new safe harbors to the federal anti-kickback statute (the “AKS”) will become effective pursuant to a final rule published by the United States Department of Health and Human Services Office of the Inspector General (the “OIG”) on December 7, 2016. The final rule also codifies safe harbors for certain AKS...

CMS FINALIZES RULE FOR EMERGENCY PREPAREDNESS REQUIREMENTS

Neal N. Peterson

The Centers for Medicare and Medicaid Services (“CMS”) published a final rule for emergency preparedness requirements for Medicare- and Medicaid-participating providers and suppliers in the Federal Register on September 16, 2016. Noting the timeliness of the rule’s publication, which also happens to coincide with peak Atlantic hurricane season,  CMS Deputy Administrator and Chief Medical Officer...