C. Frederick Geilfuss II

C. Frederick Geilfuss II

Foley & Lardner LLP

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Final Rule Will Give ACOs Participating in MSSP Access to More Data for More Beneficiaries

This is the third post in Health Care Law Today’s series on the final rule. This post addresses changes to sharing of beneficiary identifiable data. In its December 8, 2014 proposed rule revising the Medicare Shared...more

6/29/2015 - ACOs CMS Data-Sharing Final Rules Health Care Providers Healthcare Medicare Shared Savings Program

MSSP Final Rule ACO Eligibility Requirements, Application and Renewal Process

This is the second post in Health Care Law Today’s series on the final rule. This post addresses Eligibility Requirements, and the Application and the Renewal Process. ACO Eligibility Requirements - Under the...more

6/24/2015 - ACO Participant Agreements ACOs Applications Board of Directors CMS Compliance Corporate Governance Duty of Loyalty Eligibility Fiduciary Duty Final Rules Governance Standards Healthcare Healthcare Providers Medicaid Medicare Medicare Shared Savings Program Renewal Options Suppliers Transparency

CMS Releases Final Rule on Medicare Shared Savings Program

This is the first post in Health Care Law Today’s Series on the final rule. The Centers for Medicare and Medicaid Services (“CMS”) released a final rule, on June 4, 2015, addressing changes to its Medicare Shared Savings...more

6/16/2015 - ACOs CMS Final Rules Healthcare Costs Medicare Shared Savings Program SNF

CMS Announces Next Generation ACO Model

CMS announced a new ACO payment initiative on March 10, 2015, the Next Generation ACO Model, designed for entities experienced in coordinating care for populations of patients. The announcement reflects CMS’ commitment to...more

3/19/2015 - ACOs CMS Medicare Medicare Shared Savings Program Next Generation ACO (NGACO)

Tapping Into the Big Value of Health Care Big Data

In This Issue: - Executive Summary - Improving Care by Tapping Into the Data Goldmine - Big Opportunities Available in Big Data - Government Programs Supporting the Use of Big Data -...more

3/2/2015 - Big Data Healthcare PHI Popular Regulatory Standards

Cooperative Hospital Service Organizations: A Hospital Joint Venture Option

Cooperative Hospital Service Organizations (CHSOs) are organizations that are available for hospitals considering certain types of joint ventures with other hospitals. If the terms for their use strictly meet the regulatory...more

2/10/2015 - 501(c)(3) Anti-Kickback Statute Hospitals Joint Venture Safe Harbors

Iowa Insurance Commissioner Petitions for Liquidation of Iowa/Nebraska CO-OP; How Financially Sound Are Others?

The Iowa Commissioner of Insurance (the “Commissioner”) filed a petition, on January 29, 2015, seeking to liquidate CoOpportunity Health, Inc. (“CoOpportunity”), a Consumer Operated and Oriented Plan (“CO-OP”) established...more

2/4/2015 - Affordable Care Act Co-Op Health Insurance Health Insurance Exchanges Insurance Commissioners Liquidation

Affordable Care Act Co-Op Health Insurer Placed Into Rehabilitation by Iowa Insurance Commissioner

The Iowa Insurance Commissioner obtained an Order for Rehabilitation with respect to CoOportunity Health, Inc. (“CoOportunity”) on December 24, 2014. With the Rehabilitation Order, the Iowa Insurance Commission took...more

1/8/2015 - Affordable Care Act Health Insurance Insurance Commissioners Supervision

CMS Proposes Financial Revisions to MSSP to Encourage Continued and Expanded Participation

Many critics have suggested that the November 11, 2011 final rule establishing the MSSP created a financial model that over time would not be sustainable. ACOs viewed the requirement to take risk after the initial three years...more

12/23/2014 - ACOs CMS Final Rules Healthcare Medicare Shared Savings Program

CMS Releases Proposed Revised Medicare Shared Savings Program Regulations

The Centers for Medicare and Medicaid Services released, on December 1, 2014, a proposed rule to revise the Medicare Shared Savings Program (“MSSP”) Accountable Care Organization (“ACO”) Regulations. The proposed rule is...more

12/5/2014 - ACOs Affordable Care Act American Hospital Association CMS Medicare Shared Savings Program Proposed Regulation

Monetizing Real Estate: A Method to Access Capital

The financial situation for hospitals and health care organizations remains challenging. The accrediting agencies, Moody’s, Fitch, and S&P all have negative outlooks for the hospital industry. Hospitals are facing numerous...more

11/11/2014 - Capital Requirements Corporate Financing Financing Fitch Funding Health Care Providers Hospitals Moody's Real Estate Investments Recapitalization S&P

American Hospital Association Recommends Revisions to Medicare ACO Models

The American Hospital Association (AHA) submitted a letter to the Centers for Medicare and Medicaid Services (CMS) on April 17, 2014, recommending modifications to the Medicare Shared Savings Program (MSSP) and the Pioneer...more

5/2/2014 - ACOs CMS Healthcare Hospitals Medicare Medicare Shared Savings Program

Remaining Independent: A Viable Option for Community Hospitals

The environment for independent community hospitals is challenging. Government reimbursement reductions, technology enhancements and other capital demands, preparation for a changing health care system based on population...more

3/17/2014 - Healthcare Hospitals

CMS Releases Information on Success of Shared Savings Programs: Early Results Mixed and Inconclusive

On January 30, 2014, CMS released results on the Medicare Shared Savings Program (“MSSP”) and the Pioneer Accountable Care Organization Program (“Pioneer ACO Program”) for 2012, the initial performance year of each program....more

2/6/2014 - ACOs CMS Healthcare Medicare Medicare Shared Savings Program

CMS and OIG Issue Final Regulations to Extend the Stark Exception and Anti-Kickback Statute Safe Harbor for EHR Donations

On December 27, 2013, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services’ Office of Inspector General (OIG) finalized amendments to the Physician Self-Referral Law (Stark) and...more

1/17/2014 - Anti-Kickback Statute CMS EHR Healthcare HHS OIG Safe Harbors Stark Law Sunset Provisions

Win, Lose, and Push: CMS Announces First Year Results on the Pioneer ACO Program

On July 16, 2013, CMS announced results from the first performance year of the Pioneer Accountable Care Organization (ACO) Model. In the release, CMS reported that the Pioneer ACO participants held Medicare cost increases...more

7/30/2013 - ACOs Affordable Care Act CMS Healthcare Medicare Medicare Shared Savings Program Shared Savings Program

CMS and OIG Issue Proposed Rules Modifying the Stark Exception and Anti-Kickback Safe Harbor for Donation of EHR

On April 10, 2013, the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) each published proposed rules in the Federal Register...more

4/19/2013 - Anti-Kickback Statute CMS EHR OIG Proposed Regulation Stark Law Sunset Provisions

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