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What the Health Care Industry Needs to Know About the Corporate Transparency Act

A new federal law requires health care business entities to disclose personal information and photographs of persons with ownership and control over their business. The Centers for Medicare & Medicaid (CMS) and other federal...more

Supreme Court Keeps CMS Vaccine Requirement Alive Nationwide

Less than one week after hearing oral arguments, the U.S. Supreme Court has stayed injunctions against the Centers for Medicare & Medicaid Services (“CMS”) Omnibus COVID-19 Health Care Staff Vaccination Rule (“Vaccine...more

CMS Resumes Enforcement of Vaccine Requirement in Half of States

While the Centers for Medicare & Medicaid Services (“CMS”) Omnibus COVID-19 Health Care Staff Vaccination Rule (“CMS Vaccine Requirement”) heads to the Supreme Court, CMS will resume enforcement in the half of U.S. states not...more

Opponents of CMS Vaccine Mandate Secure Preliminary Injunctions Barring Nationwide Implementation

Two U.S. District Courts issued preliminary injunction orders this week barring CMS’ implementation of the Ominibus COVID-19 Health Care Staff Vaccination Rule (“CMS Vaccine Mandate”) on a nationwide basis.  The CMS Vaccine...more

CMS Vaccine Requirement Suspended During Injunctions

In the latest update to the fight surrounding vaccination of health care workers, the Centers for Medicare & Medicaid Services (“CMS”) announced that it suspended activities related to the implementation and enforcement of...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

The Privacy Survival Guide - June 2020

Polsinelli is pleased to share The Privacy Survival Guide. This newsletter is a designated source of news, information and guidance on the constantly evolving health care privacy industry. ...more

Reopening Hospital Service Lines: A Playbook for Moving Forward

The COVID-19 pandemic has created severe financial and operational difficulties for hospitals. Rapidly responding to a novel pathogen within a declared Public Health Emergency (PHE), while experiencing decreased revenues as a...more

CMS Takes Bold Action on Price Transparency & Physician Supervision in CY 2020 OPPS Proposed Rule

On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment Systems (“OPPS”) proposed rule [CMS-1717-P]. ...more

Azar v. Allina Health Services: Hospitals Claim (Procedural) Victory in DSH Dispute

On June 3, 2019, the Supreme Court issued an eagerly anticipated opinion in Azar v. Allina Health Services, a decision with far-reaching implications both for the calculation of disproportionate share payments and provider...more

Health Care Reimbursement and Payor Dispute Update - June 2019

Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry. ...more

Space Sharing Re-Boot: CMS Offers a New Approach in the State Operations Manual

On May 3, 2019, CMS published draft guidance regarding space sharing between co-located hospitals and hospitals co-located with other health care entities. ...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

Be Prepared: Provider-Based Mid-Build Audits Are Here

Hospitals with off-campus provider-based departments (“PBDs”) under construction (or “mid-build”) at the time of the Bipartisan Budget Act of 2015 – which limited Medicare payment to off-campus provider-based departments that...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

OPPS Provider-Based Final Rule — A More Practical Approach From CMS

CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”). CMS revealed the changes on November 1...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

Provider-Based Update: Congress Offers Encouraging Step to Reduce Scope of BBA Reimbursement Reductions

On Wednesday, members of the House Ways and Means Health Subcommittee introduced bipartisan legislation that would provide some welcome relief to hospitals who had already invested resources to develop new provider-based...more

Key Takeaways from FDA's New Guidance for Prescription Drug Compounders

On April 15, 2016, the Food and Drug Administration (FDA) released draft guidance that describes the FDA's interpretation of drug compounding standards under Sections 503A and 503B of the Food Drug & Cosmetic Act (FD&C Act)....more

Congress, CMS Seek Input on Provider-Based Reimbursement Reductions

Late last year, Congress made sweeping changes to Medicare provider-based reimbursement that virtually shut down any future off-campus, provider-based site developments. Section 603 of the Bipartisan Budget Act of 2015 (BBA)...more

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