Kameron Brackins

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CMS Doubles Down on Targeting Part D Enrollee Prescription Drug Abuse, But Will Stakeholders Agree?

By Kameron Brackins on Posted in Uncategorized
With the release of its 2017 draft call letter, CMS continues its push to curb opioid dependence, overdose and death among Medicare Part D enrollees. To that end, CMS proposes that Part D plan sponsors edit their benefit designs to target opioid overutilization at the point-of-sale. The letter also reminds Part D sponsors that benefit designs … Continue Reading

Providers Oppose CMS Proposal Targeting Prescription Drug Abuse by Part D Enrollees

By Kameron Brackins on Posted in Uncategorized
Providers have voiced opposition to a proposal aimed at targeting Medicare Part D enrollees with “potential opioid or acetaminophen overutilization issues that indicate the need to implement appropriate controls on these drugs for the identified beneficiaries.” Under a recently proposed rule on revised discharge planning requirements, CMS solicited comments on whether providers should be required to consult … Continue Reading

Volunteer Directors and Officers Liable to Facility Creditors

Photo of Robert M. WolinBy Robert M. Wolin and Kameron Brackins on Posted in Uncategorized
The Third Circuit Court of Appeals recently upheld a trial court’s jury verdict finding the individual board members and officers of a non-profit healthcare facility personally liable to the facility’s creditors. The board members had a false sense of security based upon the incorrect notion that board members of non-profit organizations, most of whom serve … Continue Reading
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