January 28, 2022 | By David Glaser The No Surprise Billing Act may be the most poorly written, difficult to understand set of regulations I have encountered in my legal career. Stark is much, much easier to understand. Much of the guidance out there is misleading, if not entirely wrong. Here is a short…
July 16, 2021 | By David Glaser On May 3rd CMS pulled the shared visit language from the Manuals. The government has increasingly recognized that only statutes and regulations can limit Medicare coverage, so when something in the Manuals is not contained in either a federal law or a federal regulation, it is not binding.…
January 10, 2020 | By David Glaser Skepticism is a vital trait in the coding and billing process. Constant questioning is necessary because when you receive guidance from consultants and contractors it may be both clear and categorical, but it’s possible that upon objective review, you will realize it is also cockamamie. For…
August 28, 2020 | By David Glaser, JD For the compliance-oriented, there is something rewarding about developing policies. It feels like an accomplishment, demonstrable proof of a desire to do the right thing. But speaking as a lawyer, I am convinced that most policies hurt, rather than help, the organization that adopts them. There…
January 8, 2021 | By David Glaser In early December, the Centers for Medicare and Medicaid Services (CMS) issued new rules that dramatically revise the Physician Self-Referral Law, commonly called the “Stark law” after Pete Stark, the Congressman credited with introducing it. While many of the changes loosen the law’s restrictions, focused particularly on…