C. Frederick Geilfuss II

C. Frederick Geilfuss II

Foley & Lardner LLP

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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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