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By:
Priya Bathija and
Robert Preston
 Physicians
have long provided free care or reduced rates to
financially
disadvantaged patients and as a professional courtesy to
colleagues and their families. Physicians have also
engaged in the practice of waiving insurance co-payments
and deductibles as a means of assisting patients in
managing health care costs. Recent changes to the rules
governing federal health programs and provisions in
third-party payor contracts have made these common
practices problematic and, in some instances, illegal. In
addition, due to the complexity of the laws surrounding
professional courtesy and possibly to the popularity of
the tradition, no one clear viewpoint has arisen as to its
continuing viability. This two-part series provides
physicians and other professionals with some information
on this modern dilemma through a review of the primary
federal and state laws that limit the use of professional
courtesy. Part One addresses federal law, while state
laws on professional courtesy will be covered in the July
2006 issue of the Health & Medicine Reporter.
Under federal law, physicians are generally not permitted
to waive the co-payments or deductibles required of
patients enrolled in federal health care programs,
including Medicare and Medicaid. Doing so may violate the
Stark II Regulations, the Anti-Kickback Statute or the
Civil Monetary Penalty Statute.
Stark Regulations
The Stark II Regulations (“Stark II”), which went into
effect in July, 2004, are the most recent set of
regulations to impact the ability of physicians to extend
professional courtesy. Professional courtesy is defined
in Stark II as the provision of free or discounted health
care items or services to a physician or his or her
immediate family members or office staff. Pursuant to
Stark II, a valid professional courtesy arrangement must
meet the following conditions:
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The professional courtesy is offered to all physicians
on the entity’s bona fide medical staff or in the
entity’s local community without regard to the volume or
value of referrals or other business generated between
the parties;
-
The health care items and services provided are the type
routinely provided by the entity;
-
The entity’s professional courtesy policy is set out in
writing and approved in advance by the governing body of
the health care provider;
-
The professional courtesy is not offered to any
physician (or immediate family member) who is a federal
health care program beneficiary, unless there has been a
good faith showing of financial need;
-
If the professional courtesy involves any whole or
partial waiver of any coinsurance obligation, the
insurer is informed in writing of that reduction so that
the insurer is aware of the arrangement; and
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The professional courtesy arrangement does not violate
the anti-kickback statute or any billing or
claims-submission laws or regulations.
Stark II also offers protections for private insurers who
may have concerns about professional courtesy in the form
of coinsurance waivers. The requirement to notify private
insurers of a professional courtesy arrangement provides
an additional check against abusive arrangements.
Anti-Kickback Statute
The federal Anti-Kickback Statute (the “AKS”)
makes it a criminal offense to offer, pay, solicit, or
receive any remuneration, directly or indirectly, to
induce the referral of business covered by a federal
health care program. This law prohibits any inducements
or kickbacks that could influence the decision of a
physician (or others) to refer patients, or affect a
patient’s decision to seek care. Professional courtesy
arrangements may fall within this prohibition. For
example, a surgeon who gave professional courtesy only to
physicians who referred him/her business would clearly
violate the law. Professional courtesy based on being on
the same hospital staff would raise the same issues,
although the link to the referrals would be more tenuous.
Discounts, rebates, or other reductions in price could
violate the AKS because such arrangements induce the
purchase of items or services payable by Medicare or
Medicaid. Physicians who violate the AKS are guilty of a
felony and may face severe penalties including a maximum
fine of $25,000, imprisonment of up to five years, and
exclusion from all federal health programs, including
Medicare and Medicaid.
Civil Monetary Penalty
In addition to prohibition against the waiver of
co-payments and deductibles in the AKS, the federal Civil
Monetary Penalty Statute (“CMP”)
imposes civil penalties against physicians who participate
in schemes to obtain money from federal health programs
and private third-party payors by means of false or
fraudulent statements. For example, submitting a claim
for payment in an amount higher than what the physician is
willing to accept without noting that a portion of the fee
has been waived or discounted may violate this provision.
Similarly, this offense can be triggered when a claim is
submitted which does not clearly indicate that a portion
of the fee has been waived.
The CMP specifically prohibits providers from offering any
remuneration to a patient receiving benefits under federal
health care programs that are likely to influence the
patient to receive services from the physician. The
“remuneration” includes the waiver of coinsuranceor
deductible amount and the transfer of items or services
for free or for other than fair market value. Penalties
for a violation of the CMP include significant monetary
penalties (up to $10,000 per each item or service),
treble-damages, and in extreme cases exclusion from
federal and state health care programs.
However, the prohibition against waiving co-payments and
deductibles is not absolute. The CMP allows physicians to
grant waivers in limited situations where the following
criteria are met:
1.
The waiver is not offered as part of any
advertisement or patient solicitation;
2.
The physician does not routinely waive co-insurance
or deductible amounts; and
3.
The physician waives the co-insurance and
deductible amounts after determining in good faith that
the patient is in financial need; or
4.
The physician fails to collect co-insurance or
deductible amounts after making reasonable collection
efforts 42 U.S.C. §1320a-7(a)(6).
Conclusion
Although it is not clear whether professional courtesy
will continue to be legally viable, physicians must use
careful judgment in determining whether or not to waive
co-payments and deductibles even when offered as
professional courtesy to other physicians. Under federal
laws, co-payments and deductibles should be waived for
patients enrolled in Medicare and other government
sponsored programs only if the physician complies with
Stark II, the AKS, and the CMP.
Physician providers should establish and reduce to writing
a courtesy policy that is in compliance with these federal
laws. Physician providers must also be aware of state law
provisions addressing professional courtesy. Those
provisions are equally as important and will be covered in
Part Two of this article.
______________________________
Priya Bathija is an Associate
attorney and member of the Health & Medicine Practice
Group. She can be contacted at
pbathija@bdblaw.com or
614.227.4282.
Bob Preston
is a Partner of the Health & Medicine and Trusts &
Estates Practice
Groups. He can be contacted at
rpreston@bdblaw.com or
614.227.4287.
By:
Donald Antrim
 A
recent inquiry from a physician client referenced a
question he received from a payor, presumably a managed
care company or an insurer, regarding renewing and
updating provider information. He was asked whether he
charged his patients an access fee or any other charge
beyond his professional charges for services delivered at
his office. The question from the third-party payor
addresses the tip of the proverbial iceberg in the realm
of charges for professional services. While this payor’s
inquiry may be just that, a question concerning whether
the physician is charging an access fee, the issue it
raises is the propriety of charging for “concierge
services.”
The term “concierge
services” describes the practice of charging patients,
whether they are Medicare, privately insured or private
pay individuals, for “extraordinary services.” The notion
of concierge services developed in metropolitan areas
where access to care was difficult and the willingness to
pay for that access was high. Typically associated with
primary care practices, concierge services normally
include a 24-hour pager; cell phone access; accompanying
the patient on visits to a specialist; same day, priority,
or extended-day appointments; telephone and email
consultations; and other activities connected with an
office visit.
Concierge services entered upon the radar screen of the
Office of the Inspector General (“OIG”) when the
Department of Health and Human Services concluded that
certain practitioners were charging patients for services
already covered under the Medicare program. As such,
practitioners were double-billing the patient. The
physician was accepting Medicare payment on an assignment
basis as full payment for the services rendered but
additionally charging for the allegedly non-covered
concierge services. The OIG issued an alert in March 2004
advising the practitioner community that if they are
participating providers in the Medicare program they can
charge no more for services than Medicare allows. In
addition, pursuant to the assignment rules, when they
accept payment they are accepting that amount as full
reimbursement for the services rendered. Practitioners of
concierge services maintain that these are not covered so
they need not be concerned with the reassignment
provisions and any balanced billing prohibition.
The General Accounting Office’s (“GAO”) study of concierge
services was released at the end of August 2005 and can be
found at
www.gao.gov/cgi-bin/getrpt?GAO-05-929. The GAO study
focused on the concern that the growth of concierge
services would have a detrimental impact on patient
access. The GAO report indicated that access did not
appear to be adversely affected at this time, but also
concluded that concierge services were limited, and could
be found predominantly on the east coast and in the
Pacific Northwest. The report found a variety of models
for the delivery of concierge services. The report
further found that the charge structures are as varied as
there are types of practices, ranging from modest monthly
fees for limited services, to a yearly charge in the
thousands of dollars for practically immediate access and
spa-like amenities. Some practitioners offering concierge
services remain in the Medicare program; others do not.
Obviously the safest method for offering concierge
services without running afoul of the Medicare program
would be to have the physician opt out of Medicare so
there can be no dispute as to whether the provider is
offering covered services.
A number of physicians and medical ethicists have
expressed concern about concierge services’ creating a
two-tiered health care system between those who can afford
focused care and those who cannot. The AMA Council on
Ethical and Judicial Affairs has issued a report on
“retainer” contracts that was approved by the AMA House of
Delegates in June of 2003. While the Council on Ethical
and Judicial Affairs agrees that retainer contracts are
acceptable, it raises a number of ethical concerns should
the contracts adversely affect patient access. Until
concierge services become more widespread, however, the
ethical concerns and the patient access concerns appear to
be minimal.
The question remains whether the charging of an access fee
for professional services is legally appropriate. Most
managed care provider agreements prevent the practitioner
from balanced billing (i.e., charging the
beneficiary more than the covered amount, including any
co-payment or deductibles). These contractual provisions
could be read as precluding concierge fees, membership
fees, or an access fee for the right to receive covered
and non-covered services. However, with respect to
Medicare, if the fees are solely for non-covered services,
there should be no violation of the Medicare program.
Insurance companies have differing views on concierge
services. Certain insurers, notably some of the Blue
Cross Blue Shield plans, have taken the position that
charging an extra fee for concierge services violates
balanced billing prohibitions and non-discrimination
clauses in their insurance contracts. Likewise, some
insurers have announced that they will no longer contract
with physician groups that charge an access fee .
Typically, insurance contracts have clauses which indicate
that the provider may collect a deductible or co-payment
for the delivery of the service, and no more. In the
final analysis, the propriety of an access fee comes down
to an issue of contractual compliance rather than being a
question of statutory interpretation. To determine
whether an access fee is acceptable, review your managed
care contracts and any other insurance contracts to
ascertain whether they prohibit it. If the question
remains unanswered, contact the insurance company or the
managed care representative with whom you work in order to
obtain their position with respect to charging an access
or a processing fee. A note of caution is required here
on treating an access fee or a processing fee as an
administrative fee. The Medicare fee schedules include an
administrative component such that an administrative
charge is already covered by the Medicare program. The
same issue arises in the managed care and insurance
company context if an access fee is treated as an
administrative fee, as opposed to a membership fee in a
concierge practice.
As a cautionary note, the information provided in this
article is general in nature. It is not intended to
address or solve individual problems and does not
constitute specific legal advice.
_____________________________
Don Antrim
is a Shareholder of the Health & Medicine Practice Group.
He can be contacted at
dantrim@bdblaw.com
or 614.227.4292.
Things are not looking good for specialty hospitals these
days. First, the moratorium on new –physician-owned
hospitals was extended in the recently passed budget
bill. Now, the Senate Finance Committee is weighing in on
the operation of specialty hospitals, CMS is proposing new
methods to eliminate ownership incentives in specialty
hospitals, and MedPAC is investigating whether Medicare
funds are well spent in specialty hospitals.
Finance Committee Expands Specialty Hospital
Investigation
The Senate Finance Committee wants OIG to audit patient
safety and quality of care at existing specialty
hospitals. This request came after a patient died at
Physicians’ Hospital in Portland, Oregon. According to
CMS, this hospital did not have adequate staff to monitor
and stabilize the patient’s condition after surgery.
The Senate Finance Committee also asked the Government
Accountability Office (GAO) to investigate the financial
relationships between physician owners and specialty
hospitals. Specifically, the investigation would focus on
whether physician owners are receiving more ownership
shares than their capital investments entitle them to. If
so, these arrangements would fall outside the small entity
ownership safe harbor of the Anti-Kickback Statute and
would be considered Anti-Kickback violations.
CMS to propose changes in DRG payments
The Centers for Medicare and Medicaid Services will soon
issue a proposed rule to improve the current diagnostic
related group payment system. CMS believes that the
current DRG payment system does not take into account the
acuity and severity of the patients’ diseases as well as
it could. This change is yet another change CMS proposes
in order to reduce or eliminate improper incentives to
specialty hospital owners.
MedPAC investigates if Medicare funds are well spent
in specialty hospitals
Finally, to ensure that Medicare and Medicaid funding is
well spent on care in specialty hospitals, MedPAC will
examine (1) how physician-owned specialty hospitals affect
community hospitals financially, (2) if it is more or less
expensive to treat patients at a physician-owned specialty
hospital than a full-service hospital, and (3) if
physician investors at specialty hospitals over-utilize
services.
If you have any questions regarding the status of
specialty hospitals, please contact
Don Antrim
at
614.227.4292.
Historically, the
Medicare program has provided relatively limited coverage
of outpatient prescription drugs. This all changed with
the enactment of the Medicare Prescription Drug,
Improvement, and Modernization Act of 2003 (the “Act”)—the
most significant change to the Medicare program ever to
take place. The central feature of the Act is the
establishment of a new Medicare Part D prescription drug
benefit (the “Part D benefit”), which provides broad
coverage for prescription drugs dispensed on an outpatient
basis.
The Part D benefit
became effective on January 1, 2006. With slightly over 1
million Medicare beneficiaries voluntarily choosing
coverage under one of the new stand-alone Part D drug
plans, 106 million beneficiaries being automatically
enrolled, and 6.2 million beneficiaries receiving drug
coverage through Medicaid, it is no surprise that the Part
D benefit has had a rocky start.
For example, in
January, many Part D patients left pharmacies with their
prescriptions unfilled because they were not in the
computer system yet. Federal health officials estimated
that tens of thousands of drug plan enrollees reported
difficulties filling their first prescriptions under the
new benefit during the first two weeks of operation.
Further, there is a
political debate between the states and the federal
government as to who will end up paying for the initial
problems with the Part D benefit. Several lawmakers have
introduced legislation that would reimburse states for
what they spend on Medicare drugs while the kinks are
worked out. Fifteen states, including Ohio, urged the
United States Supreme Court to immediately intervene to
resolve this dispute over other expenses associated with
the new Medicare program. The states argued that they
should not be forced to help fund the program—which could
cost them billions of dollars over the next two years.
Despite these and
other kinks in the Part D benefit, Medicare officials are
committed to fixing these problems, and the Part D benefit
is here to stay. What does this mean for physicians?
Many speculate that it will lead to physicians spending
more time on the phone with pharmacists when plans force
beneficiaries to switch to generics or to obtain prior
authorization before filling certain prescriptions.
Additionally, many physicians will need to come up with
viable clinical alternatives for expensive medications
that will not be covered to the same extent under the
Medicare benefit as they were under other types of
coverage.
There is no doubt
that the Part D benefit will bring even more red tape to
the practice of medicine—and that many physicians are
frustrated and confused as to their new role under the
Act. The Centers for Medicare and Medicaid Services has
created several tools to help physicians navigate through
this red tape in order to continue providing quality
patient care. A brief summary of these tools is included
below; however, more complete information is available on
the CMS website, at
www.cms.hhs.gov.
What’s covered; what’s not? Covered: All
plans are required to have formularies that address all
medically necessary drugs. Six drug classes of special
concern have been specified in which all or substantially
all drugs will be on a plan’s formulary: anti-neoplastics,
anti-HIV/AIDS drugs, immunosuppressants, anti-psychotics,
anti-depressants, and anti-convulsants. Not covered:
By law, there are certain types of drugs that Medicare
must exclude from Part D: barbiturates; benzodiazepines;
drugs used for anorexia, weight loss, or weight gain;
fertility drugs; drugs used for cosmetic purposes or hair
growth; cough and cold medicines; prescription vitamins
and minerals; and over-the-counter drugs.
Resources that will help you help your patients
A formulary finder that provides an easy way to access
each plan’s formulary is available at:
http://formularyfinder.medicare.gov/formularyfinder/selectstate.asp.
PDP formulary
information is also available on the Epocrates website
at:
www.epocrates.com.
Medicare Prescription
Drug Coverage Provider Communication—Request for
Prescription Information or Change form is a general fax
form to expedite communications between pharmacists and
physicians. This form is available at:
www.cms.hhs.gov/center/provider.asp.
Clarification about
Part B versus Part D drug coverage information and chart
can be found at:
www.cms.hhs.gov/pharmacy/downloads/partsbdcoverageissues.pdf.
If your patients
forget which plan they joined or still need to select a
plan, go to
www.medicare.gov and select the personal plan finder.
Enter their Medicare information. If they have joined,
this site will display the name of the plan. If not, they
can call 1-800-MEDICARE to get help in joining.
For help on
enrollment information, encourage patients to call
1-800-MEDICARE, go to
www.medicare.gov to access the plan finder, or go to
www.eldercare.gov to get information about local
organizations that can help patients with personalized
counseling.
Dedicated help for
physicians is available through CMS’s Physician’s
Regulatory Issues Team (PRIT), a group created to reduce
the regulatory burden on physicians who participate in the
Medicare Program. Physicians may e-mail questions to
PRIT@cms.hhs.gov or join in the weekly conference
calls at 2 p.m. EST every Tuesday by calling
1-800-619-2457 (Pass code: RBDML).
If you have any
questions related to the Part D Benefit, please contact
either
Priya Bathija
at
614.227.4282 or
Shila Nalawadi
at 330.491.5238.
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Tom Hess
is a member of the Health & Medicine
Practice Group and has also assumed an additional role,
that of Managing Partner of the Firm’s Columbus office.
“Over the last several years we have experienced
tremendous growth, and we plan to continue that,” Tom
explains. “We provide all the services required by clients
doing business in Ohio, regardless of headquarter
location. For example, we have several German
clients doing business in the United States. Part of my
job is to educate those clients about the services the law
firm, in its multiple locations, can provide.”
When he graduated from law school, Tom
was interested in what was then called “medicine law.”
This interest led to his first job, as an assistant
attorney general for the state of Ohio representing
many of the agencies involved in regulating the health
care industry. Tom says, “This position gave me the
perspective of the other side of the table” in dealing
with state regulatory matters. Since joining
Buckingham, Doolittle & Burroughs in 1988, Tom has
deepened this perspective in “continuous and constant
interaction with the regulators in Columbus.” He also
points out that state and federal regulations often
overlap: “You have to be conversant in both areas.”
Negotiating the vast arrays of
regulations can be very challenging. “Many times,” Tom
adds, “the quick answer is not necessarily the right
answer. The client may want to go down a certain path,
but there may be unintended consequences.” As an
example, when a client is subject to an investigation
for fraudulent billing, the inquiry can cover three
different areas:
-
Administrative law.
Either the federal or the state government could
cancel the provider’s reimbursement contracts.
-
Civil law.
The government could sue for alleged
overpayments.
-
Criminal law.
The government could make an accusation that the
contested billing was done with intent to deceive.
In cases where federal and state
regulations clash, further challenges rise because
there are no absolutes. “In a case like this, we do as
much research as possible to determine what the
federal and state governments intended. Why does there
appear to be a conflict? Is there any legislative or
judicial guidance?”
A particular focus of Tom’s practice is
nursing homes, a highly regulated industry in Ohio.
“It appears Ohio has more regulatory activity than
many other states,” Tom says. He focuses on providing
practical solutions to the nursing home’s business and
operational problems. In addition, Tom frequently
deals with issues relating to advance directives,
especially when the wishes of the family conflict with
what the law permits. Yet central to Tom’s provision
of legal advice is “always honoring and respecting the
resident’s dignity.”
A graduate of Ohio University, Tom
received his J.D. from Capital Law School.
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House oks
money for nursing home projects
Ohio’s politically
powerful nursing-home lobby won a victory last month as
the House reauthorized $10 million for capital
improvements and renovations at long-term care
facilities. The money is in House Bill 530 (“HB 530”),
the budget-corrections legislation that was signed into
law March 30, 2006. HB 530 includes revised language on
nursing home and ICF/MR capital projects that were “in
the pipeline” when the new payment system that went into
effect on July 1, 2005. HB 530 contains detailed
provisions explaining which providers qualify for
payments for pipeline capital projects and the process
for calculating and making the payments. The final
language is available at
www.legislature.state.oh.us/bills.cfm?ID=126_HB_530.
____________________________________
Congress approves new gainsharing
demonstration
Gainsharing came one step closer to being legal when
Congress gave CMS the green light to launch a new
gainsharing demonstration in 2007. This came as part of
the Deficit Reduction Act and will allow some hospitals to
share cost savings with physicians without violating the
Civil Monetary Penalty and Anti-Kickback Statutes.
The new demonstration, held at up to
six sites nationwide, will allow physicians to receive a
cut of hospital savings if they use less expensive
equipment, supplies, and protocols without hindering the
quality of are. The demonstration builds on the
gainsharing advisory opinions issued by the Office of
Inspector General in 2005.
Despite this step towards legalizing gainsharing,
gainsharing is still far from being permissible in all
situations. CMS has not defined the specifics of each of
these demonstrations at this time, and the actual
demonstration won’t begin until January 2007. Results of
this study will not be known until 2010.
____________________________________
Corporate compliance -- important
alert
The Deficit Reduction Omnibus Reconciliation Act of 2005
requires that all entities which receive or make annual
payments of at least $5,000,000 pursuant to any state
Medicaid program enact the following corporate compliance
measures:
-
Establish written policies for all employees of the entity
and any contracting agent of the entity that provide
detailed information about the Federal False Claims Act.
The policies must also detail civil or criminal penalties
for false claims and statements, and elaborate on
whistleblower protections under such laws and methods for
preventing and detecting fraud, waste, and abuse in
federal health care programs.
-
Include
as part of such written policies detailed provisions
regarding the entity’s corporate procedures regarding
fraud, waste, and abuse.
-
Include in the entity’s handbook a specific
discussion of the provisions of the Federal False Claims
Act, the rights of employees to be protected as
whistleblowers, and the entity’s corporate procedures for
detecting and preventing fraud, waste, and abuse.
The deadline for making these modifications to corporate
compliance plans is January 1, 2007. Failure to
comply with this requirement could lead to late or no
payments under the Medicare program.
OTHER NEWS
Smokers pay more for health
insurance
In response to spiraling health care costs, many health
care providers are charging extra for health insurance or
not even paying for it at all for employees who engage in
unhealthy habits—most notably, smoking. A growing number
of companies is seeing wellness as not only good for their
employees, but also good for their bottom line.
As a result, more and more companies
are losing tolerance for those perceived unhealthy
employees that would increase the individual company’s
cost of health care. In Ohio, Scotts Miracle-Gro Co.,
based in Marysville, states that it will not employ
smokers beginning later this year. Other companies across
the country have made the decision not to hire employees
who use tobacco. Some companies have made smoking
employees pay extra for health insurance. One company
based out of Tennessee, Crown Laboratories, announced that
its tobacco-using employees must pay their own health
insurance premiums in full, with no company contribution.
It is not clear whether this trend
will extend to other issues such as obesity and high
cholesterol as a natural progression to promoting
wellness. Regardless, employers must be aware of the
legal implications involved in these efforts to promote
wellness. If you have any questions about this
issue, please contact
Jan Hensel.
____________________________________
Ohio Court Says State Statute
Trumps HIPAA
The Ohio Court of Appeals for the Ninth Judicial District,
in Grove v. Northeast Ohio Nephrology Associates
(Ohio Ct. App., No. 22585, December 28, 2005), found that
Ohio Revised Code 2317.02(B)(1)—the Ohio statute
protecting privileged communications between physicians
and their patients—trumps HIPAA. The court dismissed the
plaintiff’s argument that the HIPAA privacy law preempts
the Ohio Statute. The federal rule may be preempted by
more stringent state laws. In this case, the appeals
court ruled that Ohio’s law is more stringent in
protecting patient’s privacy, and is preeminent.
____________________________________
Ohio State Auditor to Target
Medicaid Providers
Ohio State Auditor Betty Montgomery has increased efforts
to conduct audits and payment reviews of healthcare
entities receiving Medicaid funding, including hospitals,
nursing homes, health plans, pharmacies, and other
providers.
The Ohio General
Assembly authorized the state auditor to independently
select Medicaid providers for payment audits. Previously
the Ohio Department of Job and Family Services was
required to refer a provider to the state auditor before a
review could begin. Additionally, in an effort to audit a
greater number of providers each year, the State Auditor
intends to contract with private-sector consultants to
conduct the audits.
As a result of these
increased efforts to conduct audits, providers should
evaluate whether their corporate compliance plans and
Medicaid billing and documentation practices satisfy the
applicable laws.
 Richard Milligan,
Buckingham
CantonSM,
bar counsel for the Stark County Bar Association, writes a
monthly article called, "The Ethics Corner" for the
Stark County Bar Journal. The most recent
article featured the duty to report the misconduct of
other professionals.
Save the Date for these Upcoming Presentations:
April 29 -
Ronald Wilt and Robin Bravchok,
Buckingham ClevelandSM,
will be giving a presentation for the Northeast Ohio
Ultrasound Society in Independence, Ohio. Mr. Wilt
will discuss "Recent Changes in Malpractice Laws,
Including a Case Law and Legislative Update."
Ms. Bravchok's topic is "Basic HIPAA Issues."
May 4 -
Joe Feltes,
Buckingham
CantonSM,
will be speaking at the Ohio State Bar Association's
Annual Convention. His topic is "Spam I Am (Not):
Adventures and Misadventures Involving E-mail and the
Internet. What It Means to Us and Our Clients!"
May 31 -
Thomas
Hess,
Buckingham
ColumbusSM,
will be speaking
at an Ohio Health Care Association training seminar in
Columbus, Ohio. His topic will be "Advance
Directives."
July 11 -
Mark Frasure,
Buckingham
CantonSM, and
Thomas
Hess,
Buckingham
ColumbusSM,
will be presenting at a Lorman Education Services seminar
in Akron, Ohio. Their topic is
"Management of Medical Records in Ohio."
Out and About – Recent Presentations:
G.
Brenda Coey,
Buckingham CantonSM,
and Thomas
Hess,
Buckingham
ColumbusSM,
spoke at the Menorah Park Center for Senior Living
Training Center in Beechwood, Ohio. Their topic was
"Major Issues Facing Long-Term
Care Facilities." In addition, they also
presented at the Ohio Health Care Association Annual
Convention in Columbus, Ohio. They discussed
"False Claims and the Survey
Process" and "Quality
Assurance & Facility Confidentiality."
_______________________________
Joe Feltes,
Buckingham
CantonSM,
spoke at the 2006 AultCare Forum. His topic was
"The Other Pay-For-Performance." Mr. Feltes also
made a presentation to the Akron Chapter of the Society
for Human Resource Management. He discussed "Spam
I Am -- Not! The Adventures and Misadventures of
E-mail and the Internet." Finally, Mr. Feltes
presented to AultCare. His topic was "AultCare--Business
Ethics: Right Here. Right for You!"
_______________________________
Thomas
Hess,
Buckingham
ColumbusSM,
presented at a Lorman Education Services seminar in
Independence, Ohio. His topic was
"How to Survive a
Government Audit." Mr. Hess also
spoke at an Ohio Department of Health Quality
Assurance/Dementia Seminar in Columbus, Ohio. His
topic was "Understanding Ohio's
Advance Directives Protocols."
_______________________________
Richard Milligan,
Buckingham
CantonSM,
presented to the AultCare provider office managers.
His topic was "Medical
Malpractice and Your Physician Office Tips to Reduce Your
Risk."
_______________________________
Jeffrey Weinstock,
Buckingham BocaSM,
made a presentation to the Nova Southeastern University
Dental Program. His topic was
"Legal Issues for New Health Care
Professionals."
_______________________________
If you are interested in obtaining information on
upcoming seminars or would be interested in having
speakers from BDB make a presentation to your
organization, please contact: Lorna J. Henderson, Client
Relations Administrator, at
800.686.2825 ext. 86473
or
lhenderson@bdblaw.com.
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