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Hospital Outpatient Services: New CMS Supervision Requirements

Complying With the New Rules to Protect Medicare Reimbursement

Recording of a 90-minute CLE webinar/teleconference with Q&A

Conducted on Thursday, April 22, 2010
Recorded event now available

This CLE webinar will prepare healthcare counsel to guide hospitals through the implementation of the new CMS supervision requirements for outpatient services. The seminar will identify open issues the new requirements create and explain common implementation challenges.

Description

The Centers for Medicare and Medicaid Services (CMS) issued new rules effective Jan. 1, 2010 requiring on-campus hospital outpatient services to be directly supervised by an appropriately qualified physician or, in certain circumstances, by certain nonphysician practitioners (NPPs).

Complying with the rules will be challenging and costly. Hospitals must identify appropriately qualified physicians and NPPs, hire additional supervisors, and perhaps eliminate services. Consequences for noncompliance include recoupment of overpayments and possible False Claims Act violations.

Listen as our panel of healthcare attorneys explains the practical implications of the new CMS supervision requirements for outpatient services, identifies open issues the new rules create, and discusses how hospitals should respond to common supervision challenges.

Outline

Overview of new rule
1. Nonphysician practitioner (NPPs) supervision
2. Qualifications of physician or NPP
3. Therapeutic services
4. Diagnostic services
5. On-campus services
6. Off-campus services
7. Under arrangements
Compliance challenges for hospitals
1. Identifying qualified physicians and NPPs
2. Elimination of services?
Next steps for hospitals
1. Assess outpatient operations
2. Evaluate resources and physician relationships to create supervision plan
3. Review and revise supervision policies and procedures

Benefits

The panel will review these and other key questions:

How do the new CMS requirements for physician supervision of hospital outpatient services impact hospital operations?
What challenges will hospitals face in implementing the new supervision requirements?
What steps should hospitals take immediately to ensure compliance with the new rules?

Faculty

Lowell C. Brown, Partner
Arent Fox, Los Angeles

He serves as Chair of the Health Care Practice Group. He advises hospitals, health systems, long-term care facilities, medical groups and other healthcare provider organizations in business, regulatory and medico-legal matters, with an emphasis on laws relating to operational issues. He has extensive experience defending clients against actions by CMS to terminate Medicare provider agreements.

Lawrence C. Conn, Special Counsel
Foley & Lardner, Los Angeles

He represents hospitals, physicians, clinical laboratories, pharmacies, and therapy and DME suppliers on a wide range of legal issues. He has experience in health care compliance issues, including the federal Stark and anti-kickback statutes and Medicare billing and reimbursement matters. He has represented several hospitals in connection with governmental investigations and self-disclosures.

Ordering

Online CLE

Includes audio streaming of full program plus handouts (available 24 hours after live seminar).

CLE: Pre-approved for participatory or non-traditional/alternate format credit in: CA, HI*, NY*, WV*. Pre-approved for self-study credit in: AK, AZ, MO, MT, NM, TX, VT, WA.
Upon request, also available in: CO, CT*, FL, GA, ID, KY, LA, ME, NC, ND, NE, NH, NV, OR*, SC, TN, UT, WI*, WY. If you are applying for credit in one of these states, make sure to select those states when placing your order.
(*Indicates that Strafford must report attendance.)

Online CLE Audio $148.50
Available 24 hours after the live event