Matthew Fisher

What is a Board To Do?: Some Guidance from the OIG

By Matt Fisher – A practical guide for the governing boards of healthcare organizations was recently released through the joint effort of the Office of the Inspector General (“OIG”) of the Department of Health and Human Services, the American Health Lawyers Associated, the Association of Healthcare Internal Auditors and the Health Care Compliance Association.


Don’t Forget the Paper: Records and Policies

By Matt Fisher – Another HIPAA breach settlement announcement and another lesson from the Department of Health and Human Services Office for Civil Rights (“OCR”). Cornell Prescription Pharmacy (“Cornell”) is a single location pharmacy located in Colorado that will pay OCR $125,000 to resolve allegations of a variety of HIPAA violations. When the facts of the circumstances are described, it will likely raise questions as to why the settlement was so low.




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.


Training: A Necessary and Essential Part of HIPAA Compliance

By Matt Fisher – The increased focus on HIPAA compliance and anticipated second round of audits makes clear the necessity for an organization to develop and implement comprehensive policies and procedures. The many settlement and breach announcements demonstrate that many issues occur because individuals do not fully understand what HIPAA is or what it does. A lack of knowledge, however, can be combatted though with good training


Collections Allowed for Pre-Exclusion Services

By Matt Fisher – Advisory Opinion 15-02, issued by the Office of the Inspector General (“OIG”) for the Department of Health and Human Services on February 13, 2015 offers some, albeit minimal, relief for providers excluded from participation on Medicare and other federal healthcare programs.


Medicare Payment Change is A-Comin’

By Matt Fisher – The Centers for Medicare and Medicaid Services (“CMS”) made a major announcement on Monday, January 26th about payment models under Medicare. For the first time and in a very aggressive manner, CMS set a firm timeframe for implementation of alternative payment methodologies. The new timeframe furthers the goals of the Affordable Care Act in changing the manner in which healthcare is delivered and paid for in the country.