CIS Compliance Blog

By: | On: December 2, 2014 | In: CIS Compliance Blog | Government Programs
We have a new mystery date for the CMS AMP Final Rule. According to RegInfo.gov, the AMP Final Rule is scheduled for April of 2015. I don’t know, it could be a set up for an interesting April Fool’s day joke!  We shall see. For my recent blog post...
By: | On: November 25, 2014 | In: CIS Compliance Blog | Government Programs
Each year, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) publishes a work plan that lays out priorities and areas for review in the upcoming year. It’s important to recognize what the OIG plans to focus on as its efforts routinely result in billions...
By: | On: November 21, 2014 | In: Government Programs
Sometimes old news is new news and sometimes new news is old news.  In yesterday’s not very informational bulletin CMS announced: “We expect to release the finalized Affordable Care Act FULs at or about the same time that we publish the Medicaid Covered Outpatient Drug final rule (CMS-2345-F),” with...
By: | On: November 17, 2014 | In: CIS Compliance Blog | Commercial Compliance
On September 30, 2014, CMS publically published Open Payments data and needless to say, it has been a bumpy road.  With about 40 percent of records de-identified due to what CMS stated was a result of “inconsistent physician information, such as National Provider Identifier (NPI) for one doctor and...
By: | On: November 14, 2014 | In: CIS Compliance Blog | Government Programs
For your information, as posted on Reginfo.gov, the HRSA 340B “Mega Rule” (RIN: 0906-AB04) has been withdrawn. The Mega Rule, as it had come to be known, was in a proposed status, and was expected to provide some significant and much needed guidance for the PHS/340B Program, such as...
By: | On: November 13, 2014 | In: CIS Compliance Blog | Government Programs
If you are a representative of a pharmaceutical manufacturer or biotech company working in the area of Government Programs (GP), you may have received letters from Covered Entities (CE’s) regarding a refund owed to your organization. These refunds relate to historical purchases made at the Public Health Service (PHS)...
This is a follow-up to my report back in April of this year. The numbers continue to grow…. Based on the report released October 17, 2014 by the Centers for Medicare & Medicaid Services, there are approximately 8.7 million additional Americans with coverage through Medicaid and CHIP. Medicaid enrollment...
By: and | On: October 28, 2014 | In: CIS Compliance Blog | Commercial Compliance
The Art of Educating Recipients about Open Payments It has been just under a month since CMS has published its first wave of Open Payments data, and there have been many interesting effects across industry.  As with anything that’s new, there are understandably some misunderstandings about what all of...
By: | On: October 16, 2014 | In: CIS Compliance Blog | Government Programs
As previously reported, there was a final ruling in the 340B orphan drug rule litigation at the end of August. The ruling essentially held that while the HRSA’s final orphan drug exclusion rule was invalidated, HRSA’s interpretive rule issued on July 21st remained in effect. The Court stated that...
I just came across the letter the Republican leaders of the House and Senate Committees of jurisdiction sent to Centers for Medicare and Medicaid Services (CMS) Administrator Marilyn Tavenner on September 18, 2014 regarding the ongoing challenges states are facing while implementing the health law’s changes to Medicaid. I...