Value-Added Services While Avoiding Prohibited Inducements
June 22, 2019
AMARILLO, TX – Health care is evolving from the traditional “fee-for-service” (FFS) model to an “integrated care” model. Under the FFS model, health care providers (physicians, hospitals, therapists, pharmacies, DME suppliers, etc.) ope
Consignment Closets at Hospitals and Physician Offices
June 15, 2019
AMARILLO, TX – A “consignment closet” is also known as a “loan closet”…which is also known as a “stock and bill arrangement.” When a DME supplier sets up a consignment closet at a hospital/physician’s office, then this means
Big Changes are Coming to the Competitive Bidding Program
June 2, 2019
WASHINGTON, DC – In early March, CMS announced major changes to the DMEPOS competitive bidding program for 2021, including plans to consolidate the competitive bidding areas (CBAs) included in the Round 2 Re-compete and Round 1 2017 DMEPOS Comp
Telehealth: State-by-State Guidance
May 17, 2019
AMARILLO, TX – By now, most DME suppliers should know that the patient (or his/her employer or insurance company) must pay the telehealth physician; the DME supplier cannot directly or indirectly pay the telehealth physician. This is the “kic
Braces and Telehealth: Payment Suspensions
April 27, 2019
AMARILLO, TX – Two weeks ago, I wrote an article discussing the multiple arrests of individuals who were involved in selling orthotics (mostly back braces) based on telehealth encounters. According to the Department of Justice April 9, 2019 Pre
Compensating Physicians: Stark and Kickback Implications
April 21, 2019
AMARILLO, TX – Assume that a physician does not directly or indirectly generate referrals of federal health care program (“FHCP”) patients to a DME supplier. If the supplier compensates the physician for services, then neither the federal a