Leslie Demaree Goldsmith

Leslie Demaree Goldsmith

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CMS Issues DSH Ruling 1498-R2

CMS recently issued Ruling 1498-R2 (Ruling), dated April 22, 2015, amending its 2010 Ruling 1498-R. The new Ruling addresses the calculation of the Medicare fraction of the disproportionate share hospital (DSH) adjustment for...more

5/5/2015 - CMS DSH Adjustments MACs Medicare Medicare Part A PRRB Ruling 1498-R

"Next Generation" ACO Model Announced by CMS

In a March 10, 2015 press release, CMS announced a new addition to its existing Accountable Care Model (ACO) portfolio: Next Generation ACOs. As stated by CMS in its press release, this new ACO model will allow for already...more

4/9/2015 - ACOs Affordable Care Act CMS HHS Next Generation ACO (NGACO) Request for Application (RFA)

CMS Proposes Changes to the Medicare Shared Savings Program MSSP

On December 1, 2014, CMS published its proposed changes and updates to the Medicare Shared Savings Program (MSSP) for Accountable Care Organizations (ACOs). Comments are due by February 6, 2015. Below is a summary of the...more

1/9/2015 - ACOs CMS Healthcare Medicare Medicare Shared Savings Program Proposed Amendments

Highlights of the 2015 Home Health Prospective Payment Rule

On November 6, 2014, CMS published its final Medicare home health prospective payment system (HH PPS) rule for calendar year (CY) 2015. As highlighted below, notable changes in the HH PPS final rule [PDF] include: (1) a...more

12/16/2014 - ACOs CMS Healthcare Home Health Care Patient Prospective Payment System

CMS Releases Final Physician Fee Schedule Rule: Key Payment and Policy Highlights

On October 31, 2014, CMS released the final Medicare physician fee schedule (PFS) rule. The new payment policies and rates set forth in the PFS final rule will go into effect on or after January 1, 2015....more

11/17/2014 - CMS Final Rules Physician Medicare Reimbursements

CMS Releases New, Proposed Home Health Conditions of Participation

CMS published a proposed rule on Thursday, October 9th, 2014, updating the Home Health Agency (HHA) Conditions of Participation (CoPs). The proposed rule represents the first update to the HHA CoPs since 1989. Comments are...more

10/21/2014 - CMS Healthcare Home Health Agencies Medicare Participation Standards Proposed Standards

Court Affirms CMS's Adjustments to Wage Index

Deferring to CMS, the United States Court of Appeals for the Sixth Circuit recently upheld the agency’s treatment of hospitals’ payments to employees for wage index purposes. Atrium Medical Center v. U.S. Dept. of Health &...more

10/6/2014 - Appeals CMS Employer Liability Issues Hospitals Wages

CMS Publishes Proposed 2015 OPPS and ASC Payment Rule

On July 3, 2014, CMS posted the proposed CY 2015 outpatient perspective payment system (OPPS) and Ambulatory Surgical Center (ASC) payment rule, which was subsequently published in the Federal Register on July 14, 2014 [PDF]....more

7/25/2014 - CMS Healthcare Healthcare Facilities Hospitals OPPS Reimbursements Rulemaking Process

AMA Issues Telemedicine Guidelines

On June 11, 2014, the American Medical Association (AMA) released a new set of telemedicine principles, which emerged from its policy report addressing “Coverage and Payment for Telemedicine.” The AMA report details the...more

7/15/2014 - American Medical Association CMS Healthcare Reimbursements Telemedicine

CMS Announces Provider Relations Coordinator for RAC and MAC Issues

CMS recently announced that it has established a CMS Provider Relations Coordinator, Latesha Walker, to assist providers in resolution of issues with Recovery Auditor Contractors (RACs) and Medicare Administrative Contractors...more

7/11/2014 - Administrative Appointments CMS MACs RACs

Proposed Hospice Rule Focuses on Unbundling of Services

On May 8, CMS released a proposed rule in the Federal Register providing for a payment increase of 1.3 percent for fiscal year (FY) 2015. Among other provisions, CMS’s proposed rule offers hospice providers an update on...more

6/13/2014 - Bundling Rules CMS Healthcare Hospice Medicare Medicare Part D

CMS's Proposed Adoption of New Geographic Areas Likely to Have Significant Reimbursement Effects

In its proposed FY 2015 inpatient prospective payment system (IPPS) rule, CMS asserts its intent to adopt the most recent labor market area delineations issued by the Office of Management and Budget (OMB), which utilize 2010...more

5/21/2014 - CBSA Census CMS Healthcare IPPS OMB Public Comment

AHA Challenges to the Two-Midnight Rule - Preserve Your Hospital's Right to Challenge

The American Hospital Association (AHA), along with several state and regional hospital associations and several hospitals, recently filed two lawsuits challenging CMS’s two-midnight rule and related policies....more

5/6/2014 - American Hospital Association CMS Healthcare Hospitals Two-Midnight Rule

CMS's New System of Records for the Hospice Quality Reporting Program

On April 8, 2014, CMS published in the Federal Register a “Notice of a New System of Records (SOR).” CMS is establishing a new SOR titled, “Hospice Item Set System” (or HIS). ...more

4/28/2014 - CMS Healthcare Hospice

Maryland Health Care Commission Proposes to Extend and Revise EHR Incentive Regulations

On March 21, 2014, the Maryland Health Care Commission (MHCC) published proposed revisions to the existing Maryland Electronic Health Record Incentives regulations at COMAR 10.25.16. The proposed regulations [PDF] would...more

4/25/2014 - CMS EHR Healthcare Incentives Physician Payments

CMS Posts Guidance on Two-Midnight Rule and Related Audits

On February 24, 2014, CMS posted a list of updates to its guidance on the new Two-Midnight Rule and the Probe and Educate Audits. Several of the more major updates are discussed below....more

3/12/2014 - Audits CMS Healthcare MACs Medicaid Medicare

CMS Proposes Extensive Emergency Preparedness Rules

On December 26, 2013, CMS proposed emergency preparedness rules in the form of conditions of participation and conditions of coverage. These rules would apply to hospitals (including critical access hospitals), ambulatory...more

2/24/2014 - CMS Disaster Preparedness Emergency Response Healthcare Hospitals

CMS Extends Time for Probe Audits of Inpatient Admissions, and Clarifies Inpatient Order and Certification Requirements

Probe and Educate Audits of Inpatient Admissions Extended - CMS announced on its Inpatient Hospital Review website on Friday that it was extending the probe and education audits of inpatient admissions for an...more

2/7/2014 - CMS Healthcare IPPS MACs

Two Midnight Rule Updates and How to Preserve Rights to Challenge Rule

Last month, CMS updated its FAQs related to the two midnight rule. In additional, CMS conducted two recent Open Door Forum Calls related to the new rule. Some of the highlights from the updated FAQs and calls are discussed...more

1/24/2014 - CMS Hospitals Inpatient Billing Medical Reimbursement Plans Medicare

CMS Releases Guidance for MACs on 100% Prepayment and Random Medical Reviews

On October 18th, CMS issued Transmittal 489 [PDF], providing Medicare Administrative Contractors (MACs) with instructions on 100 percent prepayment and random reviews. The guidance, effective November 19, 2013, provides MACs...more

11/14/2013 - CMS Compliance Healthcare MACs Medicare

CMS Issues Additional Guidance Related to 2-Midnight Rule

Earlier this month, CMS posted three new documents related to the 2-midnight rule for inpatient admissions on its webpage for inpatient hospital reviews: new FAQs, as well as CMS directions for selecting hospital claims for...more

11/14/2013 - Audits CMS Healthcare Hospitals Inpatient Billing MACs Medicare

CMS Issues FAQs for Inpatient "2 Midnight" Rule

CMS issued its first set of FAQs on the new 2 midnight inpatient admission standards [PDF] on September 26. In those FAQs, CMS stated: - Medicare Administrative Contractors (MACs) and Recovery Auditors are not to...more

10/7/2013 - Admissions CMS Healthcare Hospitals Medical Liability Medicare Recovery Audit

CMS Issues Inpatient Admission Order and Certification Guidance

On September 5th of this year, CMS issued guidance [PDF] addressing hospital inpatient admission orders and certifications. The regulations addressing certifications at 42 C.F.R. §§ 424.13 – 424.16 were revised as part of the...more

9/23/2013 - CMS Hospitals Medicare Patient Prospective Payment System

Earlier Deadlines for Wage Index Development Process

CMS has changed the timetable in the wage index development process for FY 2015. The FY 2015 Hospital Wage Index Development Timetable and the preliminary wage index files can be found here (see alert for link)....more

9/20/2013 - CMS Deadlines Indexing Wages

CMS Adopts Final Rules for Inpatient Admissions and Inpatient Part B Billing

In its final IPPS rule for FY 2014 CMS adopts its earlier proposals regarding its two-midnight policy related to inpatient admissions and hospital billing under Part B following a denial of an inpatient stay. CMS discusses...more

8/27/2013 - CMS Hospitals Inpatient Billing Medicaid Medicare

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