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Seminar: Contracting with Physicians While Complying w/ DHCS' IMS Guidelines: Avoid Costly Mistakes
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When: April 30, 2018 at 10:00 am - 1:00 pm PST
Where: Nelson Hardiman Conference Facilities, West Los Angeles
Pricing: $75 for Non-Members / $50 for AATA Members


Register by phone at (888) 958-2282

Collaboration between physicians and treatment programs is generally considered a benefit to patient care. To that end, California law changed in October 2015 to allow licensed healthcare practitioners at residential treatment facilities to provide "incidental medical services" (IMS), which are defined as:

  • (i) obtaining medical histories;
  • (ii) monitoring resident health status to determine the need for emergency or urgent care;
  • (iii) detoxification testing;
  • (iv) providing alcoholism/drug abuse recovery/treatment services;
  • (v) overseeing patient self-administered medication; and
  • (vi) treating substance use disorders, including detoxification.

Residential facilities interested in providing incidental medical services must apply to the Department of Health Care Services (DHCS) before providing any such services.

Incidental medical services at residential treatment facilities must be provided by one or more physicians and surgeons licensed by the Medical Board of California or the Osteopathic Medical Board or by licensed health care practitioners acting within the scope of practice of their licensure and under the direction of a physician and surgeon. The healthcare practitioners providing IMS must be knowledgeable about addiction medicine.

Residential treatment facilities who engage healthcare practitioners to provide IMS need to have a comprehensive understanding of the law that permits IMS as well as DCHS’ recent guidelines and upcoming regulations. Mistakes in this area – such as contracting with physicians to provide broader primary care or psychiatric care to their clients at your facility – can put your license (and the physician’s license) at risk and can potentially result in violations of California’s corporate practice of medicine law (CPOM), which generally prohibits licensed health professionals from working for business entities other than professional corporations or for unlicensed people. Furthermore, mistakes in this area can result in health insurance companies denying claims for reimbursement and placing your facility on their audit lists.

Facilities also need to make sure that they have a robust and thorough credentialing process for the physicians and other healthcare practitioners that they hire to provide IMS. If a patient care problem arises with the provision of IMS, your facility could potentially face significant liability for negligent credentialing

Some of the seminar’s highlights:

  • A review of California’s CPOM law and what it means for your program or your practice
  • A clear understanding of the scope of permissible IMS versus prohibited practice of medicine at residential treatment facilities
  • DCHS’ guidelines and anticipated regulations for IMS
  • The intersection of IMS and insurance reimbursement, and best practices to maximize reimbursement
  • Best practices for IMS contracts and understanding the legal relationship between the residential treatment facility and the physician
  • Best practices for credentialing practitioners of IMS
  • Q&A with the presenters

Let Nelson Hardiman and AATA, your resource for addiction treatment compliance education, walk you through these issues and more.

*NOTE: Members must be logged into the AATA website for discount pricing.


Register by phone at (888) 958-2282


Kathryn F. Edgerton

Kathryn F. Edgerton

Kathryn F. Edgerton is a transactional and regulatory attorney with Nelson Hardiman. Ms. Edgerton has built a significant practice advising hospitals, physician organizations, addiction treatment and behavioral care providers, long-term health providers, telemedicine providers, home health providers, medical spas, and other health-related organizations on the complex transactional and regulatory issues impacting the healthcare industry. Drawing on her experience as counsel to approximately 70 addiction treatment providers, Ms. Edgerton brings a practical perspective to her work advising on day-to-day operational issues, as well as business and regulatory concerns. Ms. Edgerton successfully obtained licensure, certification, and accreditation for a host of facilities regulated by the California Department of Health Care Services (DHCS), the California Department of Social Services (DSS), and the California Department of Public Health (CDPH), including substance abuse treatment facilities, group homes, adult residential facilities, congregate living health facilities, and home health agencies.

John A. Mills

John A. Mills

Navigating between regulatory compliance and litigation, the versatility of John A. Mills' healthcare practice and the diversity of his clients provide him with a keen understanding of the unique business objectives and risks facing different segments of the healthcare provider community. His regulatory compliance work focuses on key issues facing providers that could potentially impede their business operations. He advises clients on managed care and ERISA compliance, voluntary disclosures of possible Medicare over-payments, medical staff and peer review, analysis of business arrangements to ensure compliance with the anti-kickback and Stark laws and provides regulatory guidance to covered entities and contract pharmacies in connection with the federal 340B program. Among Mr. Mills' diverse range of clients are hospitals, ambulatory surgery centers, addiction treatment centers, community clinics and 340B covered entities, healthcare districts, physicians and other healthcare professionals, medical groups and IPAs, peer review bodies, management service organizations and medical billing companies, and pharmacies.

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American Addiction Treatment Association
11835 W Olympic Blvd
Los Angeles, CA 90064
(888) 958-2282

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Nelson Hardiman represents healthcare providers, including hospitals, physician organizations, long-term and behavioral care providers, and other healthcare-related organizations, in business litigation, transactions, and regulatory matters. Although we are based in California, our attorneys are routinely asked to advise business organizations that are national in scope. For more than 20 years, our lawyers have focused on regulatory compliance, litigation, and transactions specific to the healthcare industry. We combine specialized experience in a wide range of healthcare sectors with a proactive and attentive approach, making us the most effective choice for healthcare legal matters.

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