Late yesterday, HHS/OCR released revised guidance on tracking technologies. Their original guidance in 2022 sparked confusion and led to a lawsuit filed by the American Hospital Association. While the revised guidance provides some clarity, I believe they still overstep by concluding that potential future patients’ information can constitute PHI. I've outlined the differences between the 2022 Guidance and the Revised Guidance in my latest blog post. A link is in the comments below. #HIPAA
Dena M. Castricone, CIPP/US, CIPM’s Post
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Is the 75th Percentile FMV, regardless of productivity? For those of you who live in the healthcare regulatory compliance space, I wanted to get your opinion on the recent Community Health Network, Inc. (CHN) case. In case you’re not familiar with it, CHN ignored guidance from their valuation consultants regarding physician compensation. One of their valuation firms essentially advised CHN that physician compensation at or below the 75th percentile (of national survey data) was FMV regardless of productivity. What are your general thoughts on this?
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Director @ VMG Health | Physician Compensation Expert Email Me: [email protected]
The answer is no for a couple of reasons. 1) CMS basically said as much in their 2021 Stark Law changes, which stated that it is not CMS' policy that anything below the 75th percentile is OK and anything above is suspect. FMV is based on the facts and circumstances of a particular arrangement. 2) Productivity is only one element of value - access, quality, patient experience, cost of care and a multitude of other factors all matter when determining the fair market value of a particular arrangement.
Is the 75th Percentile FMV, regardless of productivity? For those of you who live in the healthcare regulatory compliance space, I wanted to get your opinion on the recent Community Health Network, Inc. (CHN) case. In case you’re not familiar with it, CHN ignored guidance from their valuation consultants regarding physician compensation. One of their valuation firms essentially advised CHN that physician compensation at or below the 75th percentile (of national survey data) was FMV regardless of productivity. What are your general thoughts on this?
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Medical Director @ Urban Pathways | Founder, CEO & President @ SWEET Institute | Physician Educator | Columbia University | Executive Council Member of the NY District Branch of the APA | Trustee
Contingency management delivers not just modules, but pathways to possibility, turning challenges into opportunities, and fostering a culture of resilience and growth.
Delve into the world of patient experiences with mobile telephone-delivered contingency management (mCM) in our seminar "Contingency Management to Promote Adherence: Part II." Join us live on Monday, May 20, 2024, from 7-8pm EDT, as we uncover the qualitative insights into patients' beliefs, expectations, and perceived benefits of mCM interventions. . Register now and gain valuable insights to enhance your clinical practice! https://lnkd.in/djZAWi6f . . . #contingencymanagement #adherence #patientperspectives #mhealth #behaviorchange #addictiontreatment #qualitativeresearch #ceus #clinicalpractice #substanceusedisorder #technologyintervention #patientcare #onlinelearning #healthcareeducation #sweetinstitute
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Delve into the world of patient experiences with mobile telephone-delivered contingency management (mCM) in our seminar "Contingency Management to Promote Adherence: Part II." Join us live on Monday, May 20, 2024, from 7-8pm EDT, as we uncover the qualitative insights into patients' beliefs, expectations, and perceived benefits of mCM interventions. . Register now and gain valuable insights to enhance your clinical practice! https://lnkd.in/djZAWi6f . . . #contingencymanagement #adherence #patientperspectives #mhealth #behaviorchange #addictiontreatment #qualitativeresearch #ceus #clinicalpractice #substanceusedisorder #technologyintervention #patientcare #onlinelearning #healthcareeducation #sweetinstitute
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Did you miss "Adverse Action Reporting: The Consequences Of A Permanent Record," part 3 of our Exploring Hospital and Physician Dynamics webinar series? Listen on-demand here:
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Did you miss "Adverse Action Reporting: The Consequences Of A Permanent Record," part 3 of our Exploring Hospital and Physician Dynamics webinar series? Listen on-demand here:
Exploring Hospital and Physician Dynamics Web Series Part 3 - Adverse Action Reporting
frierlevitt.com
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Did you miss "Adverse Action Reporting: The Consequences Of A Permanent Record," part 3 of our Exploring Hospital and Physician Dynamics webinar series? Listen on-demand here:
Exploring Hospital and Physician Dynamics Web Series Part 3 - Adverse Action Reporting
frierlevitt.com
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Digital Health Leader | AI & Clinical Integration Expert | Champion of Healthcare Digitization & Value-Based Care | Technology & Service Delivery Optimization | Value-Based Care |
Measuring what matters. PROMs/PREMs and patient-directed surveys to identify opportunities and create clarity in patient-directed care. An important, and often missed opportunity to objectify MSK care and create a 360-degree view of the clinical experience.
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Access over 470 critical care questions with #CHESTSEEK that can help advance your clinical knowledge and improve problem-solving skills. https://hubs.la/Q02wqnxy0
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This week on Sg2 Perspectives, host Trevor DaRin sits down with Sg2 Senior Director Casi Roethler, MBA, MHA, FACHE to talk all things primary care: what they’re seeing, what they’re hearing, what data they’re tracking, and what may change about primary care in the near- and long-term. Trevor and Casi touch on the consumer shift, employed vs independent physicians, and what the primary care landscape could look like in 5 or 10 years. https://bit.ly/4bmYXmP
Making Sense of the Primary Care Landscape
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Privacy and Healthcare Attorney
5moBlog post: https://dmclawllc.com/2024/03/19/the-pixel-problem-part-2-tracking-technologies-and-ocrs-revised-guidance/