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Provider Reimbursement Disputes Go Back to 1984 Following Supreme Court’s Regulatory Reset

One could forgive the healthcare industry for thinking someone drove Doc Brown’s DeLorean time machine through One First Street when it awoke on Friday, June 28, to a blast from the past....more

Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review

The Centers For Medicare & Medicaid Services Issues New Inpatient Prospective Payment System Final Rule - On September 3, 2020, the Centers for Medicare & Medicaid Services (CMS) issued the fiscal year (FY) 2021 Medicare...more

Health Care Reimbursement and Payor Dispute Update - August 2020

Introduction - CMS has taken extensive measures to assist providers and promote access to care in light of the Public Health Emergency (PHE) related to the COVID-19 pandemic. The efforts taken have and continue to benefit...more

CMS Targets Off-Campus Provider-Based Departments in 2019 OPPS Proposed Rule

On Wednesday July 25, 2018, the Centers for Medicare and Medicaid Services (CMS) released an advance copy of the CY 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. ...more

Hospital Medicare Certification at Risk? CMS Clarifies Inpatient Volume Expectations

Hospitals with dangerously low inpatient volume and micro hospitals focused primarily on the delivery of outpatient and/or emergency room services instead of inpatient services beware: CMS (Centers for Medicare and Medicaid...more

Feb. 13 Deadline Looms for Provider-Based Departments Seeking Mid-Build Exception

A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (off-campus PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build...more

Jan. 31 Deadline: Off-Campus Provider-Based Relocations Requests

For relocations that occurred between 11.2.15 and 12.31.16, providers must submit relocation requests by 1.31.2017. The CY 2017 OPPS Final Rule brought significant changes to the way Medicare reimburses hospitals for...more

CMS Proposes Amendments to Payments Furnished from Provider-Based Departments

As part of the CY 2017 proposed Hospital Outpatient Prospective Payment System rules (OPPS) the Centers for Medicare and Medicaid Services (CMS) released the long awaited proposed payment changes for items and services...more

60-Day Overpayment Reporting Final Rule—The Rule of Six

On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged...more

Provider-Based Status: A Quiet Casualty of the Bipartisan Budget Act

Without fanfare or any significant discussion, the Bipartisan Budget Act (Act) contains the first legislative action related to provider-based status—and it is a sweeping action with negative financial consequences to many...more

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