TAG:
stark law
Are Feds Ready to Strike at TC/PC Arrangements?
By Robert Michel | From the Volume XIV No. 12 – August 27, 2007 Issue
CEO SUMMARY: Pathologists and laboratory directors will want to pay attention to the proposed rules published by the Centers for Medicare and Medicaid Services on July 2, 2007. The document is a grab bag of proposals and rules that would significantly curb many common ancillary services a…
Technical/Professional Billing Has Risks for Labs, Doctors
IT’S A HOT TOPIC ACROSS THE ANATOMIC PATHOLOGY PROFESSION. Increasing numbers of physician groups are hiring laboratories to perform the technical component of an anatomic pathology case and engaging pathologists to diagnose the cases. This phenomenon is often called TC/PC, to repr…
Technical/Professional Billing Split Is A Threat to Pathology
By Robert Michel | From the Volume XIII No. 3 – February 27, 2006 Issue
EACH SECOND YEAR, when we publish our bi-annual trends in anatomic pathology, we get feedback from our clients and regular readers. This year, a particularly insightful letter was received. The writer wants to add another trend to our list of 11. He puts forth his arguments in the letter we reproduc…
Barristers Offer Insights Into OIG Opinion 04-17
By Robert Michel | From the Volume XII No. 3 – February 14, 2005 Issue
CEO SUMMARY: This is an intelligence briefing which tries to “read between the lines” and: 1) provide useful information about the OIG’s “undeclared” views on physician self-referral issues, particularly as they relate to anatomic pathology condominiums; and, 2) how specialist p…
Bi-Annual Look at Trends Reshaping Clinical Labs
By Robert Michel | From the Volume XII No. 2 – January 24, 2005 Issue
CEO SUMMARY: Among other things, we declare the end to the heyday of the independent commercial lab company which offers a broad test menu to all types of office-based physicians. In its place springs forth the specialty or niche testing laboratory. Small and focused on a specific number …
OIG Releases Opinion On AP Lab Condominiums
By Robert Michel | From the Volume XII No. 1 – January 3, 2005 Issue
CEO SUMMARY: In responding to a request for an advisory opinion, the Office of the Inspector General (OIG) issued an advisory opinion which declares that anatomic pathology (AP) lab condominiums “could potentially generate prohibited remuneration under the anti-kickback statute.” It a…
Analysis of OIG’s Opinion Shows Compliance Shift
By Robert Michel | From the Volume XII No. 1 – January 3, 2005 Issue
CEO SUMMARY: Attorney Richard Cooper believes the latest Advisory Opinion by the Office of the Inspector General (OIG) is consistent with its earlier anti-kickback law pronouncements about situations where a physician is in a position to profit from the patients he/she refers. Cooper also…
Catfight in New York Over Lab Supplies Law
By Robert Michel | From the Volume IX No. 5 – April 1, 2002 Issue
CEO SUMMARY: All labs serving physicians’ offices worry about the delicate balance between complying with laws governing inducement and protecting clients against competing labs who interpret those same laws more liberally. Recent events in New York state graphically demonstrate the com…
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Volume XXXII, No. 6 – April 21, 2025
Now that a federal judge has vacated the FDA’s LDT rule, The Dark Report analyzes the judgement and notes the various steps the FDA could take in response. Also, lab testing at pharmacies is proving to be less successful than was once anticipated.
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