The Peril of Policies

  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…

Shared Visits

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.…