CMS Rolls Out a General Provider Telehealth and Telemedicine Tool Kit

Information from CMS for medical providers on telehealth and telemedicine

Information from CMS for medical providers on telehealth and telemedicineBy: Susan St. John

CMS has rolled out a telehealth/telemedicine tool kit to assist medical professionals with health care delivery during the current COVID-19 public health emergency.

The toolkit contains information and links concerning:

 

  • 1135 Waivers – allows the Secretary of HHS to temporarily waive or modify certain Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) requirements to ensure sufficient health care services and items are available to meet the needs of individuals enrolled in Social Security Act programs during the emergency and that providers who provide services in good faith can be reimbursed and exempted from sanctions (provided there is no determination of fraud and abuse). 1135 waiver or modifications include:
    • Conditions of participation and other certification requirements;
    • Program participation and similar requirements;
    • Preapproval requirements;
    • State licensing requirements where services are rendered as long as the provider has equivalent licensing in another State (for Medicare, Medicaid, CHIP reimbursement only; State licensing still controls whether a non-Federal provider may provide services in a state he/she is not licensed in);
    • EMTALA sanctions for redirection for medical screening, as long as redirection is not the result of discrimination on the basis of a patient’s source of payment or ability to pay;
    • Stark self-referral sanctions;
    • Adjustment (not waiver) to performance deadlines and timetables;
    • Limitations on payment to permit Medicare enrollees to use out of network providers in an emergency situation.

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Starting Healthcare Business: What to Consider

By: Jeff Cohen

As a healthcare business lawyer, I’ve seen nearly everything entrepreneurs think might be a good idea.  They usually come to me when starting a healthcare business with questions like:

  1. Do you like an LLC better than an Inc., and if so why;
  2. Does the Stark Law (or the Anti-Kickback Statute) allow us to do this?;
  3. Is it ok to allocate ownership and profit distribution differently?;
  4. Will insurers pay for this?; and
  5. WWMT?  (What Would Medicare Think?).

These are great questions.  And they’re off base.  In fact, they’re not only off base. They’re also out of order.  Here’s one for you–Continue reading