Fwd: legality of self-referral by transitionalist in homehealth service
Divya Dhar
Sent from my iPhone
Begin forwarded message:
From: "Duffy, Erin M." <EMD...@duanemorris.com>
Date: April 16, 2013, 8:06:29 PM EDT
To: Divya Dhar <divya...@gmail.com>, "Cohen, Richard L." <RLC...@duanemorris.com>
Cc: "Clark, Lisa W." <LWC...@duanemorris.com>
Subject: RE: legality of self-referral by transitionalist in homehealth service
I think the most important thing for you to understand at this point is the Medicare Conditions of Payment/Participation for Home Health agencies because that will really dictate whether this model is feasible and what you need to do to operate within the guidelines. With Stark and Anti-kickback we can give you some general advice on compliance issues and structure. Let me know if that works for you. Erin
Erin M. Duffy
Duane Morris LLP
30 South 17th Street
Philadelphia, PA 19103-4196
From: Divya Dhar [mailto:divya...@gmail.com]
Sent: Tuesday, April 16, 2013 6:25 PM
To: Cohen, Richard L.
Cc: Duffy, Erin M.; Clark, Lisa W.
Subject: Re: legality of self-referral by transitionalist in homehealth service
Dear Erin
Great talking to you. I know I asked you the estimate for what this will cost and you said max $3000. Iv just asked my team and that's above our budget. We are wondering what you can tell us for $1000.
If our client likes our work, we will make sure to let them know we used you for service and that's likely to get Duane morris more business as this project proceeds.
Please let me know what you think.
Best
Divya
Sent from my iPhone
On Apr 16, 2013, at 3:11 PM, "Cohen, Richard L." <RLC...@duanemorris.com> wrote:Divya, Erin Duffy who you met is going to give you a call to get some additional background from you. She will be able to quickly determine how Stark and Anti-kickback intersect with the home health conditions of payment/participation in this situation, but will need all the facts.
Richard L. Cohen
Duane Morris LLP
30 South 17th Street
Philadelphia, PA 19103-4196
P: 215.979.1233
F: 215.689.1982RLC...@duanemorris.com
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From: Divya Dhar [mailto:divya...@gmail.com]
Sent: Tuesday, April 16, 2013 2:48 PM
To: Cohen, Richard L.
Subject: legality of self-referral by transitionalist in homehealth service
Dear Richard
I'm contacting you on behalf of my school project team. We are investigating the role of a transitionalist (doctor) in a home healthcare service (currently run by nurses).
In particular we want to know what the law says about self-referrals. I know about stark and anti-kick back. But i specifically want to learn if those that are discharged under our home health care with only 2 week of care, can be seen by our traditionalist who can extend this period to the maximum 60 days. Normally this extension is done by the patient's PCP but we would like to do it in house if we can do so legally.
I'm contacting a couple of law firms to ask if they have expertise in this area and can talk to me ASAP.
Best regards
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