We previously noted that the No Surprises Act (NSA) regulation’s establishment of the presumption that the qualifying payment amount (QPA)—generally, the median payment by the plan to providers in the region—is the...more
On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) issued its Calendar Year (CY) 2022 Physician Fee Schedule (“PFS”) Final Rule. In this post, we sample some key highlights from the Final Rule. ...more
12/23/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
FQHC ,
Health Care Providers ,
Healthcare ,
Healthcare Reform ,
Medicare ,
MPFS ,
Physician Fee Schedule ,
Rural Health Care Program ,
Self-Referral ,
Stark Law ,
Telehealth ,
Telemedicine
In a November 12, 2021 revision of its prior draft guidelines for hospital co-location compliance with Medicare conditions of participation (COP) for hospitals (QSO-19-13), CMS has apparently softened its approach to...more
This post reviews Part II of the federal No Surprises Act regulations. In previous publications, we have commented upon the No Surprises Act, and Part I of the regulations.
The “Requirements Related to Surprise Billing;...more
In a FAQ published on August 20, 2021, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) significantly delayed implementation of statutory requirements on surprise billing...more
9/3/2021
/ Affordable Care Act ,
Consolidated Appropriations Act (CAA) ,
Delays ,
Health Care Providers ,
Health Insurance ,
Healthcare Reform ,
Hospitals ,
Price Transparency ,
Public Disclosure ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Requirements ,
Surprise Medical Bills
As discussed in a prior post, the Hospital Price Transparency Rule at 45 C.F.R. § 180.10 et. seq. (the “Rule”), requires all hospitals to provide clear, accessible pricing information about the items and services they provide...more
This post provides an update to our previous publication summarizing the federal No Surprises Act and is part two of two in a series on new interim regulations implementing certain requirements of the No Surprises Act.
In...more
This post provides an update to our previous publication summarizing the federal No Surprises Act and is part one of two in a series on new interim regulations implementing certain requirements of the No Surprises Act....more
This post is part one of two in a series on new transparency requirements impacting both health plans and health care providers.
In an effort to assist patients in understanding the cost of hospital services, the Hospital...more
As promised, this is a follow-up to our first blog post on the new federal transparency requirements. In our prior post, we summarized the Hospital Price Transparency rule which went into effect on January 1, 2021, and here...more
On October 9, 2019, the Department of Health and Human Services ("HHS") issued proposed changes to the regulations implementing the Physician Self-Referral Law (the "Stark Law"), the Anti-Kickback Statute (the "AKS"), and the...more
10/15/2019
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Department of Health and Human Services (HHS) ,
EHR ,
Exceptions ,
Health Care Providers ,
Healthcare Reform ,
OIG ,
Proposed Amendments ,
Stark Law ,
Value-Based Care
Yesterday, the Supreme Court heard oral argument in King v. Burwell, which some describe as an argument over a mere four words – "established by the state." But to the surprise of many, the Justices did not spend most of the...more