(By accessing, browsing or using the pages below, you agree to the Blog Conditions of Use/Disclaimer available under "Links.")
CMS has finalized a rule that expands Medicare coverage for telehealth services. This final rule, along with other new rules and waivers by the federal government, state governments and private payors, has significantly expanded access to and coverage of virtual health care services in response to the public health emergency. READ MORE
On May 3, 2019, CMS issued long-awaited draft guidance addressing co-location arrangements, providing some clarification on how a hospital can share space, services, staff and emergency services and still demonstrate independent compliance with the Medicare Conditions of Participation for hospitals (“COPs”). READ MORE
The broad scope of CMS’s recent Request for Information gives health care providers an opportunity to voice their concerns on a variety of Stark Law provisions, and may demonstrate an interest within the administration to modify the regulations implementing this statute. READ MORE
On Jan. 9, 2018, the Centers for Medicare and Medicaid Services (CMS) announced a new voluntary episode-payment program, Bundled Payments for Care Improvement Advanced, which allows health care providers to accept risk for the cost of care associated with a clinical episode “based on how successfully they manage resources and total costs.” READ MORE
In August, CMS issued a proposed rule seeking to reduce mandatory participation requirements in the CJR program and eliminate the episode payment models and CR incentive payment model before their scheduled effective date. READ MORE
After earlier delays, the Centers for Medicare and Medicaid Services has set the start date for cardiac episode payment models and revisions to the Comprehensive Care for Joint Replacement to Jan. 1, 2018. READ MORE
If you are in the process of drafting a Self-Referral Disclosure Protocol submission, you must use CMS' new SRDP forms or risk the agency not accepting the disclosure into the protocol. READ MORE
At the end of November, CMS will prohibit long-term care facilities from using pre-dispute arbitration agreements and only allow arbitration when a dispute arises on a voluntary basis. But a federal judge in Mississippi has already granted a request to bar CMS from implementing the rule. READ MORE
Given the increased emphasis on the ACO governing body’s work in the Final Waivers, it is paramount that ACO Boards work thoughtfully through this evaluative process, documenting its consideration, analysis, and conclusions in formal Board minutes. READ MORE
The three key requirements that the Final Rule clarified and which all providers participating in Medicare Part A and Part B must know are: (a) when is an overpayment identified by a provider, (b) what is the required lookback period for returning overpayment, and (c) what process must be used to refund an overpayment. READ MORE
With the continued focus of the government on investigating and prosecuting matters involving compliance with the Stark Law, health care systems entering into compensation arrangements with referring physicians must have robust processes in place to ensure that the compensation arrangements – at the time that they are structured and during the course of the arrangement – don’t run afoul of the Stark Law. READ MORE
Hospitals affected by the CCJR model proposal will need to address a number of opportunities and challenges rather quickly. READ MORE
HCPLAN is intended, in part, to “identify areas of agreement” for new payment models and reporting methods. More generally, it would seem, HCPLAN has the challenge of working to define value for healthcare delivery, to determine how to measure value and then how to pay for that value. This is no small task/ READ MORE
Effective April 6, 2015, in response to a pre-payment review and additional documentation request issued by a MAC or ZPIC, providers and suppliers will be limited to a 45 calendar day timeframe to produce the requested documentation and should no longer have any expectation that a request for an extension of time will be granted. READ MORE
Since our report last week, “Next steps under open payments,” the Centers for Medicare & Medicaid Services (“CMS”) has released additional information on the time frame for registration on CMS’ Enterprise Portal for physicians and teaching hospitals. READ MORE
As manufacturers and group purchasing organizations (“GPOs”) get ready for Phase 2 of Open Payments (formerly, the Physician Payments Sunshine Act), physicians and teaching hospitals should be aware that a voluntary registration process to enable them to review data submitted by manufacturers and GPOs through Open Payments will soon follow. READ MORE
NOTICE.
Although we would like to hear from you, we cannot represent you until we know that
doing so will not create a conflict of interest. Also, we cannot treat unsolicited
information as confidential. Accordingly, please do not send us any information
about any matter that may involve you until you receive a written statement from
us that we represent you (an ‘engagement letter’).
By clicking the ‘ACCEPT’ button, you agree that we may review any information you transmit to us. You recognize that our review of your information, even if you submitted it in a good faith effort to retain us, and, further, even if you consider it confidential, does not preclude us from representing another client directly adverse to you, even in a matter where that information could and will be used against you. Please click the ‘ACCEPT’ button if you understand and accept the foregoing statement and wish to proceed.
