New Jersey Passes Telemedicine & Telehealth Law

September 27, 2017

On July 21, 2017, New Jersey passed a law that specifically allows NJ licensed health care practitioners to: (1) deliver treatment and establish a practitioner/patient relationship through telemedicine, and (2) in many situations, be paid for such services in the same manner as in-person treatment. For many NJ licensed practitioners and mental health screeners, as …

IRS Revokes Hospital’s Tax Exemption: A Shot Across the Bow

IRS’ Stepped-Up Enforcement Efforts.  The IRS recently posted its first published letter revoking the tax-exempt status of a hospital due to failure to comply with section 501(r) of the Internal Revenue Code.  (Revocation 2017-31014 at https://www.irs.gov/pub/irs-wd/201731014.pdf.)  This revocation is the IRS’ stark reminder that the multi-faceted compliance requirements of 501(r), enacted  in 2010 as part …

Changes to NJ Medicaid Pharmacy Reimbursement and 340B

August 9, 2017

New Jersey Medicaid issued two Newsletters describing a change to reimbursement at actual acquisition cost (AAC) for fee-for-service (FFS) Medicaid claims, a new professional fee applicable to retail and long-term-care pharmacy services, and required claim level identification of drugs purchased at the 340B discount (the “Newsletters”).[1] Also, in response to recent communications from certain Medicaid …

CMS Proposes Cut for 340B Hospitals

August 3, 2017

On July 13, 2017, in its Calendar Year (CY) 2018 Hospital Outpatient Prospective Payment System (OPPS) Proposed Rule, the Centers for Medicare & Medicaid Services (CMS) issued a surprise proposal to reduce 340B reimbursement for certain Medicare Part B drugs purchased by 340B-eligible hospitals, hospitals, community mental health centers, and ambulatory surgical centers, starting January …

New State Department of Health Regulations Require a Hospital to Develop Policies and Procedures if it Allows Patients to Bring In and Self-Administer Medical Marijuana

June 23, 2017

New York State Department of Health (DOH) regulations took effect on May 17, 2017 that require hospitals to develop policies and procedures if they allow patients to bring in and self-administer medical marijuana. The DOH regulations require that the hospital’s policies and procedures address security of the medical marijuana product, verification that the patient is …