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What is Shannon Wiley looking forward to at this year's Asembia Specialty Pharmacy Summit? Find out more>


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Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Download the Healthcare Fraud & Abuse Review 2017, authored by Bass, Berry & Sims

The Healthcare Fraud & Abuse Review 2017 details all healthcare-related False Claims Act settlements from last year, organized by particular sectors of the healthcare industry. In addition to reviewing all healthcare fraud-related settlements, the Review includes updates on enforcement-related litigation involving the Stark Law and Anti-Kickback Statute, and looks at the continued implications from the government's focus on enforcement efforts involving individual actors in connection with civil and criminal healthcare fraud investigations.

Click here to download the Review.

Breathing Room For Now: CMS Defers Implementation of Final SNF and NF Ownership Disclosures


August 11, 2011

In an earlier edition of Health Law Update,1 we reported that the Centers for Medicare & Medicaid Services ("CMS") had issued a proposed rule, published as part of the proposed skilled nursing facility prospective payment system ("PPS") update for fiscal year 2012,2 which would require certain ownership disclosures for Medicare skilled nursing facilities ("SNFs") and Medicaid nursing facilities ("NFs"). These ownership disclosure requirements would be in addition to the ownership disclosure requirements appearing in the expanded Form 855A that CMS published on its website at the beginning of July 2011.3

Earlier this week, CMS published in the Federal Register the final rule for the SNF PPS for fiscal year 2012 (the "Final Rule").4 In the Final Rule, CMS has deferred the implementation of the proposed ownership disclosure requirements for SNFs and NFs in order to respond properly to all of the comments it received regarding those provisions of the proposed rule. CMS intends to finalize these provisions in a separate final rule to be published in early 2012, prior to its statutory deadline of March 22, 2012.5

1  See "855 Fun, Part II: SNFs and NFs Face Additional Ownership Disclosures," July 28, 2011.
2  76 Fed. Reg. 26364 (May 6, 2011).
3  See "855 Fun, Part I: CMS’ New Provider Enrollment Applications," July 26, 2011.
4  76 Fed. Reg. 48486 (Aug. 8, 2011).
The Patient Protection and Affordable Care Act, Section 6101(3), as amended by the Health Care and Education Reconciliation Act.

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