Regulatory Issues

Gathering Feedback on the Certification Rule

By John Halamka MD – Over the next 3 months, the HIT Standards Committee will review every detail of the 431 page Certification rule. We’ll also be holding calls to look at the rule as a whole. At least one call will be open to the general public. Think of this as reviewing the “trees” and the “forest”.

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OIG Announces Multi-year Meaningful Use Audits Coming Soon

By Jim Tate – Lost in the furor and excitement of the recently released Proposed Stage 3 MU Rule something slipped by us. Robert Frost would say it “came on little cat feet”. John Lennon would say it came in “like a lizard on a window pane”. What is it that crept in through the cracks in the floor and why should we care?



Concerns for Preferred Provider Agreements

By Matt Fisher – Advisory Opinion 15-04 issued by the Office of the Inspector General (“OIG”) on March 25, 2015 offers some warnings when entering into preferred provider agreements. The new Advisory Opinion arose in the context of laboratory services, but the principles discussed are easily applicable to any preferred provider arrangement. The advice and insight are important in light of the increasing desire among providers to identify and enter into preferred provider agreements.