Monday, October 3, 2011

Interesting Article About Something We Hadn't Thought Of

Although it's hardly our primary topic of interest (in fact, we've called it boring), the infernally complex, changing, and potentially extremely expensive (if the statute is violated) issue of Medicare Secondary Payer registration and reporting.  Our prior posts on the subject are here.

We saw an online article not too long ago (although, by now, not too recently either) on an aspect of MSP liability that we hadn't even considered.  Because we hadn't considered it, we suspected that a lot of our readers might not have either.  That topic is whether drug companies and others who conduct clinical trials are considered "insurance plans" under the terms of the MSP.  Our initial reaction, that "that's so far afield from what the statute was about as to be ridiculous," may well have been incorrect.  Apparently there is some movement inside the Centers for Medicare & Medicaid Services to include clinical trials within the MSP's onerous requirements and add still more expense to the development of new drugs, medical devices and vaccines.  But don't take our words for it, because we don't pretend to be experts in this.  Read the article instead.  You may be as surprised (and appalled) as we were.