Anna Grizzle
Nashville
Healthcare compliance, investigations and regulatory attorney.
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Articles by Anna Grizzle
CMS Announces Change Healthcare/Optum Payment Disruption (CHOPD) Accelerated Payments To Part A Providers And Advance Payments To Part B Suppliers
Recognizing the ongoing impact of the cyberattack experienced by Change Healthcare/Optum on February 21, 2024, the Centers for Medicare & Medicaid Services (CMS) announced over the weekend that it will allow Part A providers to apply for accelerated payments and Part B suppliers to apply for advance payments if experiencing claims disruptions as a result of the cyberattack.
CMS Announces Change Healthcare/Optum Payment Disruption (CHOPD) Accelerated Payments to Part A Providers and Advance Payments to Part B Suppliers | JD Supra
Recognizing the ongoing impact of the cyberattack experienced by Change Healthcare/Optum on February 21, 2024, the Centers for Medicare & Medicaid Services (CMS) announced over the weekend that it will allow Part A providers to apply for accelerated payments and Part B suppliers to apply for advance payments if experiencing claims disruptions as a result of the cyberattack.
HHS Releases Groundbreaking General Compliance Program Guidance, Setting New Standards For Healthcare Entities
On November 6, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) released the most up-to-date, comprehensive, and practical general compliance guidance in decades. The new General Compliance Program Guidance is a 91-page document that contains valuable summaries of relevant laws, generally applicable compliance program basics, key resources, and practical tips.
HHS Releases Groundbreaking General Compliance Program Guidance, Setting New Standards for Healthcare Entities | JD Supra
On November 6, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) released the most up-to-date, comprehensive, and practical general compliance guidance in decades. The new General Compliance Program Guidance is a 91-page document that contains valuable summaries of relevant laws, generally applicable compliance program basics, key resources, and practical tips.
[Webinar] 9th Annual Nashville Healthcare Fraud Conference - December 14th - 15th, 9:00 am - 2:00 pm CST | JD Supra
Please join us for the 9th Annual Nashville Healthcare Fraud Conference hosted by Bass, Berry & Sims and the Tennessee Hospital Association. Eligible for more than seven hours of CLE credit (including ethics), this complimentary program will take place on December 7 in Nashville (full day). The conference will be broadcast virtually on the mornings of December 14 and 15.
HHS-OIG Year in Review - 2022 | JD Supra
The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) continues to offer valuable insights to the healthcare industry as to how best to approach increasingly complex healthcare fraud and abuse issues. Please see full Publication below for more information. Download PDF
2022: HHS-OIG Year In Review
Stewart Kameen advises healthcare clients on all aspects of federal and state healthcare laws and regulations, with a particular emphasis on fraud and abuse regulatory counseling, corporate compliance, internal investigations and government enforcement actions, qui tam litigation, and transactional matters.
2022: HHS-OIG Year In Review
Introduction The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) continues to offer valuable insights to the healthcare industry as to how best to approach increasingly complex healthcare fraud and abuse issues. Bass, Berry & Sims is pleased to share this HHS-OIG Year In Review (HHS-OIG YIR) that highlights key guidance OIG issued in 2022, as well as other items of import involving the agency.
The ABCs of Medicare and Medicaid Claims Audits: Navigating the Medicare and Medicaid Appeals Process and Challenging Adverse Audit Results
As addressed in the prior installments of this three-part series (Understanding the Audit Contractors and Responding to Audits and Potential Consequences from Negative Audits), healthcare providers face potential audits from an increasing number of Medicare and Medicaid contractors, often with significant financial and other consequences. This content – the final in a three-part alert series – explores the appeals process, tips for achieving the best results and challenging adverse audit results.
The ABCs of Medicare and Medicaid Claims Audits: Responding to Audits and Potential Consequences from Negative Audits | JD Supra
As addressed in the first installment of this three-part series, healthcare providers face potential audits from an increasing number of Medicare and Medicaid contractors. Failing to respond properly can lead to significant and sometimes draconian consequences. This content – the second in a three-part alert series – explores how best to respond to audits and the potential consequences that can result from negative audit results.
The ABCs of Medicare and Medicaid Claims Audits: Responding to Audits and Potential Consequences from Negative Audits
As addressed in the first installment of this three-part series, healthcare providers face potential audits from an increasing number of Medicare and Medicaid contractors. Failing to respond properly can lead to significant and sometimes draconian consequences. This content – the second in a three-part alert series – explores how best to respond to audits and the potential consequences that can result from negative audit results.
CMS Audits: Part 1 The ABCs of Medicare and Medicaid Claims Audits: Understanding the Audit Contractors | JD Supra
Because Medicare and Medicaid claims audit requests can look like routine billing-related correspondence, they can be easy to miss, leading to expensive and potentially catastrophic consequences. Providers, therefore, should be prepared to identify and promptly and diligently respond to any audit requests from government contractors.
CMS Audits: Part 1 The ABCs of Medicare and Medicaid Claims Audits: Understanding the Audit Contractors
Because Medicare and Medicaid claims audit requests can look like routine billing-related correspondence, they can be easy to miss, leading to expensive and potentially catastrophic consequences. Providers, therefore, should be prepared to identify and promptly and diligently respond to any audit requests from government contractors.
11th annual Healthcare Fraud & Abuse Review 2022
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We are pleased to bring you our 11th annual Healthcare Fraud & Abuse Review. Our Review provides comprehensive coverage of the most significant civil and criminal enforcement issues facing healthcare providers. Each year, we endeavor to cover key enforcement initiatives, analyze important case developments and document healthcare fraud settlements across the industry, and present those topics in a readily digestible format for our readers.
By Angela Bergman, Kristin M. Bohl, J. Taylor Chenery, Matthew M. Curley, Lindsey Brown Fetzer, Lauren Gaffney, Scott Gallisdorfer, Jeff Gibson, Anna Grizzle, Brian Irving, Stewart W. Kameen, Travis Lloyd, William T. Mathias, Jennifer Michael, Lisa S. Rivera, Brian Roark, Glenn Rose, Molly Ruberg, Danielle Sloane, Julia Tamulis, Nathan Brown, Hannah Choate, Maleaka Guice, Dee Harleston, Sheaniva Murray, Heather Pearson, Brianna Powell, Peter Rathmell, Taylor Sample, Rhea Shinde, Page Minton Smith, Briana Sprick Schuster, Jamie Steakley, Hannah C. Webber, Abby Yi, John C. Eason, Michael K. Bassham, Garrah Carter-Mason
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Lexology
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Court Once Again Strikes Down Payer-Friendly Provisions in Surprise Billing Regulations | JD Supra
On February 6, the U.S. District Court for the Eastern District of Texas vacated key provisions in the regulations implementing a federal arbitration process to settle out-of-network (OON) payment disputes between payers and providers. The decision is the third time a federal court has ruled in favor of providers challenging the implementation of the arbitration process created under the No Surprises Act (NSA), referred to as the independent dispute resolution (IDR) process.
Payment Due: HRSA Seeks Repayment of Provider Relief Funds for Non-Compliance | JD Supra
The Health Resources and Services Administration (HRSA) is seeking repayment of Provider Relief Fund (PRF) payments from providers who failed to submit the required report(s) on their use of the funds.
Payment Due: HRSA Seeks Repayment of Provider Relief Funds for Non-Compliance
The Health Resources and Services Administration (HRSA) is seeking repayment of Provider Relief Fund (PRF) payments from providers who failed to submit the required report(s) on their use of the funds.
OIG Approves Hospital Provision of Nurse Practitioner Services in Advisory Opinion | JD Supra
January 6, 2023 Anna Grizzle, Travis Lloyd, Jennifer Michael, Angelique Salib Bass, Berry & Sims PLC + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services recently posted Advisory Opinion 22-20, approving an acute care hospital’s arrangement under which its employed nurse practitioners perform certain services that the patients’ primary care...
No Surprises Act Update: HHS Extends Enforcement Discretion for Co-Provider Good Faith Estimates | JD Supra
On December 2, the Department of Health and Human Services (HHS) announced it would not begin enforcement of a key requirement under the No Surprises Act (NSA) starting January 1, 2023, as previously scheduled. The enforcement delay relates to a portion of the NSA requirement for facilities and providers to furnish a good faith estimate (GFE) of expected charges to uninsured and self-pay individuals.
No Surprises Act Update: HHS Extends Enforcement Discretion for Co-Provider Good Faith Estimates
On December 2, the Department of Health and Human Services (HHS) announced it would not begin enforcement of a key requirement under the No Surprises Act (NSA) starting January 1, 2023, as previously scheduled. The enforcement delay relates to a portion of the NSA requirement for facilities and providers to furnish a good faith estimate (GFE) of expected charges to uninsured and self-pay individuals.
New Year Brings Significant Changes To Medicare Physician Fee Schedule
To print this article, all you need is to be registered or login on Mondaq.com. The Medicare Physician Fee Schedule Final Rule for Calendar Year 2021 (the Final Rule) issued by the Centers for Medicare & Medicaid Services (CMS) on December 1, 2020, and published in the Federal Register on December 28, 2020, made significant and far-reaching changes to the Medicare Physician Fee Schedule (PFS).
New Year Brings Significant Changes to Medicare Physician Fee Schedule | JD Supra
The Medicare Physician Fee Schedule Final Rule for Calendar Year 2021 (the Final Rule) issued by the Centers for Medicare & Medicaid Services (CMS) on December 1, 2020, and published in the Federal Register on December 28, 2020, made significant and far-reaching changes to the Medicare Physician Fee Schedule (PFS).
HHS Changes Course: Requires Repayment of Excess Relief Funds Received | JD Supra
On December 4, the U.S. Department of Health and Human Services (HHS) revised its Public Health and Social Services Emergency Fund (Relief Fund) Frequently Asked Questions (FAQs), indicating that providers must return Relief Fund monies received in excess of amounts calculated using HHS’s Relief Fund payment formulas.
HRSA Releases Details on Provider Relief Fund Reporting Requirements | JD Supra
The Health Resources and Services Administration (HRSA) quietly released a Post-Payment Notice of Reporting Requirements (Notice) over the weekend, which provides some initial details regarding the reporting requirements applicable to CARES Act Provider Relief Fund (PRF) recipients that accepted one or more payments exceeding $10,000 in the aggregate.
HHS Issues Guidance Regarding Relief Fund Reporting and Auditing Requirements | JD Supra
The U.S. Department of Health and Human Services (HHS) recently issued new guidance regarding reporting and auditing requirements that may impact providers and suppliers who retain payments received from the Public Health and Social Services Emergency Fund (Relief Fund). The guidance clarifies reporting requirements outlined in the Terms and Conditions (T&C) and the applicability of auditing requirements found in existing HHS regulations.
OBOT Program Changes: New Tennessee Laws Allow NPs and PAs to Prescribe Buprenorphine and Impose New Financial | JD Supra
As Tennessee continues to look for options to expand access to opioid treatment services, a new Tennessee law expands the types of providers who may prescribe medication-assisted treatment and imposes certain financial obligations on all providers who prescribe buprenorphine.
Waiver of Patient Cost-Sharing Obligations for Telehealth Services During COVID-19 Pandemic | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Takeaways from the DOJ’s 2019 False Claims Act Report
The DOJ recently released its annual report on False Claims Act enforcement, and FCA enforcement shows no signs of slowing. Bass, Berry & Sims’ Taylor Chenery, Lauren Gaffney and Anna Grizzle discuss what the report reveals. 2020 marks the 150th anniversary of the Department of Justice (DOJ), and based on a recently released 2019 report, its FCA enforcement efforts show no signs of slowing, with health care fraud recoveries undoubtedly continuing to make up the bulk of recoveries.
Update: Third Circuit Allows Allegations of Improper Compensation under the Stark Law to Proceed, but Reverses Controversial “Varies with Volume or Value” Reasoning | Bass, Berry & Sims PLC - JDSupra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Update: Third Circuit Allows Allegations of Improper Compensation under the Stark Law to Proceed, but Reverses Controversial "Varies with Volume or Value" Reasoning | LexBlog
On December 20, 2019, the U.S. Court of Appeals for the Third Circuit granted in part a petition for rehearing filed by the University of Pittsburgh Medical Center (UPMC) in a False Claims Act (FCA) case that has generated considerable attention among hospitals and health systems due to its treatment of commonplace, productivity-based physician compensation models.
CMS Finalizes Highly Anticipated Hospital Price Transparency Rule | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Third Circuit Holds Allegations of Improper Compensation Methodologies under the Stark Law Survive Motion to Dismiss | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CMS Proposal Vastly Expands Medicare Coverage for Opioid Treatment | JD Supra
On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) took the first steps toward welcoming opioid treatment programs (OTPs) into the Medicare program and expanding Medicare coverage of opioid use disorder (OUD) treatment services provided by both OTPs and physician practices. These steps are a welcome development for providers trying to address the growing opioid epidemic.
HEALTHCARE FRAUD & ABUSE REVIEW 2018 | Lexology
Hospitals and Health Systems Hospice Home Health SNFs and Nursing Homes Pharmaceutical and Device Pharmacy Services Managed Care/Insurance Laboratory, Pathology, Radiology and Diagnostics Behavioral Health and Substance Abuse Treatment Services Specialty Care and Other Provider Entities Medical Transportation Individual Providers 74. ABOUT BASS, BERRY & SIMS A LOOK BACK....
Congress Takes Action to Curb the Opioid Crisis | JD Supra
JD Supra Privacy Policy Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Judicial Opinions Support Delay of Recoupment from Audit Appeals Until After ALJ Hearings in Certain Circumstances | JD Supra
Recent opinions by the Fifth Circuit, the Northern and Southern Districts of Texas, and the District of South Carolina offer hope to providers seeking relief from substantial monetary recoupments during the Medicare appeals process. The uptick in audits by Medicare contractors, such as Zone Program Integrity Contractors (ZPICs), over the past several years has caused a significant backlog in the Medicare claims appeal process.
Stark Under the Microscope: Congress and HHS Examine Reform of the Stark Law for a Value-Based System | JD Supra
On July 17, 2018, the U.S. House of Representatives' Ways and Means Committee Subcommittee on Health ("Subcommittee") expressed its commitment to modernizing the Stark Law1 during a hearing in which industry and government witnesses shared concerns about the inhibiting effect of the Stark Law on innovative payment models and value-based care.2 Although the Subcommittee members and witnesses expressed varying concerns and options for reform, the hearing reflected a largely bipartisan consensus...
CMS Offers Expanded Settlement Options to Reduce Appeals Backlog | JD Supra
In January 2018, Centers for Medicare & Medicaid Services (CMS) announced additional information regarding a new Low Volume Appeals (LVA) settlement option and an expanded Settlement Conference Facilitation (SCF) as part of its efforts to reduce the significant backlog of appeals pending before Administrative Law Judges (ALJs) at the Office of Medicare Hearings and Appeals (OMHA) and the Medicare Appeals Council (Council).
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