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Something for Everyone - 2017 OIG Work Plan Update

Each year, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) releases a Work Plan (WP) that assesses risks to HHS programs and operations in the coming year, and, consequently, prioritizes the sequence and proportion of resources allocated.   Because the WP is published late in the prior year, updates are made throughout the current WP year to reassess priorities and anticipate and respond to new issues.  Historically, the OIG updated its WP once or twice per year; now, however, the OIG applies monthly updates to its WP and publishes it on its website.  Since June 2017, the OIG has published 37 updates  - this Health Capital Topics article will review some of the key updates to the 2017 OIG WP that focus on reimbursement issues related to various healthcare enterprises and services.
Each year, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) releases a Work Plan (WP) that assesses risks to HHS programs and operations in the coming year, and, consequently, prioritizes the sequence and proportion of resources allocated.   Because the WP is published late in the prior year, updates are made throughout the current WP year to reassess priorities and anticipate and respond to new issues.  Historically, the OIG updated its WP once or twice per year; now, however, the OIG applies monthly updates to its WP and publishes it on its website.  Since June 2017, the OIG has published 37 updates  - this Health Capital Topics article will review some of the key updates to the 2017 OIG WP that focus on reimbursement issues related to various healthcare enterprises and services.   (Read more...) 
The value of a non-compete clause (NCC) in a physician employment agreement (PEA) arises from the restriction placed upon the employed physician by the NCC. In the absence of the arrangement, the physician would be free to provide professional medical services to patients regardless of the time period or geographic location.  When a physician has entered into a PEA with an NCC, the physician is restricted in their ability to provide professional medical services at sites of service which are deemed as competitors to the employing entity. 

These restrictions can be viewed from both a physician (seller) and the employing entity (buyer) perspective. From the physician's perspective, the NCC limits the physician's ability to provide services. A reasonable methodology for determining the amount that a physician (willing seller) would demand to enter into an agreement with an NCC might be to determine the magnitude of the lost profits, on a present value basis, that would likely arise from the physician's post-employment restricted practice. However, this methodology is hampered by regulatory restrictions, such as the Stark Law and Anti-Kickback Statute, which forbid an employing entity from paying physicians for the volume or value of referrals.   (Read more...) 
Approximately 17 percent of the U.S. gross domestic product (GDP) is comprised of healthcare, more than any other country in the world per capita. The U.S., however, realizes poorer health outcomes than other developed countries on numerous measures.  One of the main factors for high healthcare expenditures is the rising price of prescription drugs.  Between the years of 2013 and 2015, prescription drug net spending increased by 20 percent,  which currently comprises an estimated 16.7 percent of all healthcare costs.  These rising costs do not affect prescription drug consumers exclusively, as 40 percent of prescription drug expenditures are covered by government payors, increasing the national budget and burdening taxpayers.  Two reasons are cited as the main factors for rising drug costs: (1) protection from competition; and, (2) uneven negotiating power.  In this first installment of a two-part series on rising prescription drug costs, these two reasons for rising drug costs are explored.  
The opioid epidemic poses a significant threat to the public health, such that, to date, six states have issued emergency declarations in response to opioid misuse (i.e., addiction). In an attempt to hinder prescription opioid misuse, regulatory and legislative authorities, as well as the courts, have taken action by tracking prescriptions, controlling the supply of opioids, and policing the marketing of these drugs, among other enforcement activities.

In an attempt to combat prescription drug misuse, states have developed and implemented Prescription Drug Monitoring Programs (PDMPs). A PDMP is a statewide electronic database that collects data on certain drugs dispensed throughout the state and distributes this data to individuals authorized under law to receive this information. Data collection and reporting vary across states, but by tracking prescription and patient histories, PDMPs may help to identify patients who may be diverting or abusing opioids and other drugs. State reports on the success of PDMPs have indicated that PDMPs have had a positive impact by reducing the number of patients receiving prescriptions from multiple physicians simultaneously, also known as "doctor shopping." Currently, PDMPs are implemented in every state (including Washington, D.C.), with the exception of Missouri.  (Read more...)
ANNOUNCING
 
Advanced Distance Education to Launch in 2017

The Institute for Healthcare Valuation (IHV) & Consultants' Training Institute (CTI) are pleased to announce premier healthcare valuation training through a distance education program, the Certificate of Educational Achievement (CEA) for Advanced Education in Healthcare Valuation. The program will launch in the summer of 2017 and will bridge the interdisciplinary nature of healthcare valuation to include: the Four Pillars of Healthcare (regulatory, reimbursement, competition, and technology); the market forces shaping the U.S. healthcare industry; and the valuation of healthcare enterprises, assets, and services. Legal professionals and healthcare providers, as well as those wishing to expand their scope of activities in healthcare valuation engagements and those seeking to enhance their current healthcare valuation service lines, will gain comprehensive knowledge through completing the expansive program. The program has been developed and is being presented by industry thought leaders Robert James Cimasi, MHA, ASA, MCBA, FRICS, CVA, CM&AA, Chief Executive Officer, and Todd A. Zigrang, MBA, MHA, FACHE, ASA, President of Health Capital Consultants, alongside a blockbuster faculty of healthcare subject matter experts from the legal, federal regulatory, and valuation professions.
HCC CEO Bob Cimasi Recognized as a "Pioneer of the Profession" 
under NACVA's "Industry Titans" Awards

HCC CEO Robert James Cimasi, MHA, ASA, FRICS, MCBA, CVA, CM&AA, has been
named a "Pioneer of the Profession," by the National Association of Certified Valuators and Analysts (NACVA) and Consultants Training Institute (CTI) as part of their Silver Anniversary recognition luncheon of valuation "Industry Titans," which distinguishes those whom have had the greatest impact on the profession.  Mr. Cimasi joins valuation profession luminaries, including: Dr. Shannon P. Pratt, Chris Mercer, James R. Hitchner, Roger J. Grabowski, Richard Wise, Jay E. Fishman, Nancy Fannon, Honorable Judge David Laro, Howard Lewis, and Mel H. Abraham, along with fourteen others, in receiving this honor. Congratulations to Bob Cimasi and his fellow "Pioneer of the Profession" honorees from the HCC Team and Topics Staff!