New at Noyce Consulting

What About Gifts Cards and Gift Certificates?

Beth Noyce

  This anti-kickback clarification could keep your staff out of jail. I wanted you to see it. What About Gifts Cards and Gift Certificates? A key question for providers, especially marketing staff members, is whether they can give referral sources gift cards or gift certificates. This question is equally important for referral sources that may be offered gift cards or gift certificates by providers to which they make referrals. The answers to these questions are based on the federal antikickback statute, which says, in part:   "(1) Whoever knowingly and willfully solicits or receives any remuneration (including any kickback, bribe, or rebate)...


OCR Issues Guidance on HIPAA, Health Information Exchanges, and Disclosures of Protected Health Information for Public Health Purposes

Beth Noyce

When important government data comes out, I want you to know about it. Here's an article NAHC published January 5. OCR Issues Guidance on HIPAA, Health Information Exchanges, and Disclosures of Protected Health Information for Public Health Purposes On Friday, December 18, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) issued guidance on how the Health Insurance Portability and Accountability Act of 1996 (HIPAA) permits covered entities and their business associates to use health information exchanges (HIEs) to disclose protected health information (PHI) for the public health activities of a public health...


CMS COVID-19 Vaccine Preparation

Beth Noyce

Comments 320

CMS has released an update on COVID-19 vaccine preparation. Here is the link: https://public-inspection.federalregister.gov/2020-24332.pdf?utm_campaign=pi+subscription+mailing+list&utm_source=federalregister.gov&utm_medium=email


2021 Home Health Final Rule

Beth Noyce

Just wanted to make sure you knew! The 2021 Home Health Final Rule was published today at https://public-inspection.federalregister.gov/2020-24146.pdf?utm_medium=email&utm_campaign=pi+subscription+mailing+list&utm_source=federalregister.gov


How to Avoid Denials and Adverse Audit Results Based on Homebound Status

Beth Noyce

Comments 3

Medicare-certified home health agencies are justifiably concerned about recent fraud and abuse initiatives that target homebound status. Agency managers perceive that they are extremely vulnerable regarding this issue for at least two key reasons: (1) the standards used to determine homebound status remain ill-defined; and (2) because Medicare homecare services are provided only intermittently, as opposed to continuously, agencies are unable to verify homebound status with absolute certainty.    Nonetheless, the Health Care Financing Administration (HCFA), the Office of Inspector General (OIG), and intermediaries are intent on holding agencies’ “feet to the fire” on this issue. On October 5, 2020, for example,...