C. Frederick Geilfuss II

C. Frederick Geilfuss II

Foley & Lardner LLP

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Latest Publications


Payor/Provider Convergence: Joint Venture Health Plans

Health Plans and health care providers are getting into each other’s business. This payor/provider convergence has taken different forms. Health systems have ventured into the health insurance business by acquiring or...more

3/17/2017 - Health Care Providers Health Insurance Joint Venture Provider Payments

Rand Corporation Issues Report on U.S. Blood System

“A robust, sustainable blood system is a crucial component of every health care system.” That is how Rand Corporation’s recently issued comprehensive report entitled “Toward a Sustainable Blood Supply in the United States”...more

2/8/2017 - Medical Reports Public Health

CMS Finalizes Mandatory Cardiac Care Bundled Payment Model and More

On December 20, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (the Final Rule) which includes three new mandatory episode-based payment programs for cardiac care, as well as the expansion of the...more

1/3/2017 - Affordable Care Act Bundled Payments CCJR CMS Final Rules Medicare Medicare Access and CHIP Reauthorization (MACRA) Medicare Shared Savings Program

IRS Denies Exempt Status for Non-MSSP Accountable Care Organizations

In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”)....more

7/15/2016 - 501(c)(3) ACOs Affordable Care Act Exempt Organizations Health Care Providers Hospitals IRS Medicare Shared Savings Program Physicians Private Letter Rulings Third-Party Unrelated Business Income Tax

DOJ and North Carolina Challenge Anti-Steering and Tiering Provisions in Managed Care Contracts

The Department of Justice’s antitrust division (the “DOJ”)and the State of North Carolina (“NC”) jointly sued, on June 9, 2016, Carolinas HealthCare System (“CHS”), the largest healthcare system in North Carolina, over...more

6/22/2016 - Anti-Steering Rules Antitrust Division Competition DOJ Health Insurance Insurance Contracts Managed Care Contracts Sherman Act

CMS Announces Latest Alternative Payment Model - Comprehensive Primary Care Plus

Continuing in its efforts to promote alternative payment models, on April 11, 2016, CMS announced the Comprehensive Primary Care Plus (CPC+) model. CMS hopes to implement CPC+ in up to 20 regions, accommodating up to 5,000...more

4/22/2016 - Alternative Payment Models (APM) CMS Comprehensive Primary Care (CPC+) Health Care Providers Health Information Technologies MPFS Physicians

Comprehensive Joint Replacement Bundled Payment Program Begins April 1st

Approximately 800 hospitals in 67 Metropolitan Statistical Areas will begin mandatory participation in the Comprehensive Care for Joint Replacement (CJR) Model on April 1, 2016. The CJR bundled payment program applies to...more

3/9/2016 - Bundled Payments CCJR CMS Collaboration Health Care Providers Hospitals Medicare Value-Based Payments

CMS Proposes Additional Changes to MSSP Regulations

The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule modifying the Medicare Shared Savings Program (MSSP) regulations (the “Rule”). Among other changes, the Rule proposes (a) to modify the...more

2/19/2016 - ACOs CMS Comment Period Fee-for-Service Health Care Providers Medicare Shared Savings Program Proposed Regulation

Top Three Reasons ACOs Should Use Telehealth and Telemedicine

Accountable Care Organizations (ACOs) can share costs of telehealth and remote patient monitoring services among their hospitals, providers/suppliers, and other ACO participants, according to federal regulations under the...more

11/3/2015 - ACOs Alternative Payment Models (APM) CMS Fee-for-Service Fraud and Abuse Health Care Providers Health Information Technologies Healthcare Healthcare Reform Hospitals Medicare Medicare Shared Savings Program OIG Suppliers Telehealth Telemedicine Value-Based Purchasing Waivers

OIG and CMS Issue Rule: Finalizing Fraud and Abuse Waivers for MSSP ACOs

The Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) of the Department of Health and Human Services just issued a final rule setting forth waivers of specified fraud and abuse laws...more

11/2/2015 - ACOs CMS Final Rules Fraud and Abuse Gainsharing Healthcare Home Health Care Medicare Medicare Shared Savings Program OIG Required Documentation Waivers

2014 Medicare ACO Results Released: CMS Asserts Success but Few ACOs Receive Payments

The Centers for Medicare and Medicaid Services (CMS) released, on August 25, 2015, the quality and financial performance results for Medicare Accountable Care Organizations for 2014. CMS touted that Medicare ACOs continued to...more

9/10/2015 - ACOs Alternative Payment Models (APM) Bundled Payments CMS Electronic Medical Records Health Care Providers Healthcare Costs Medicare Medicare Shared Savings Program Physician Medicare Reimbursements Quality of Care Standards

Medicare Advantage Value-Based Insurance Design Model

CMS, through the Center for Medicare and Medicaid Innovation, announced on September 1, 2015, the introduction of the Medicare Advantage Value-Based Insurance Design (VBID) Model as part of the Health Plan Innovations...more

9/4/2015 - Beneficiaries CMS Comment Period Cost-Sharing Health Insurance HMOs Innovation Medicare Medicare Advantage PPOs Quality of Care Standards Supplemental Benefits Value-Based Purchasing

MSSP Final Rule Provides Modification to Shared Savings Financial Arrangement

This is the fifth post in Health Care Law Today’s series on the final rule. The final Medicare Shared Savings Program (“MSSP”) rule released on June 4, 2015, contains a number of modifications to the financial...more

7/15/2015 - ACOs CMS Final Rules Medicaid Medicare Medicare Shared Savings Program Value-Based Purchasing

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 Health Care Providers Healthcare 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

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