Thomas W. Coons

Thomas W. Coons


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Challenges to Medicare's Outlier Payment Rules - the Secretary Largely Prevails

As we reported in an earlier Payment Matters article, the United States Court of Appeals for the District of Columbia Circuit handed hospitals a partial victory on May 19, 2015, in their challenge to Medicare outlier payments...more

10/30/2015 - Appeals Arbitrary and Capricious Banner Health System Hospitals Medicare Outlier Payment Rules Regulatory Standards Rulemaking Process Secretary of HHS

CMS Prevails in Dual Eligible Bad Debt Challenge

In a decision handed down on August 7, 2015, the United States Court of Appeals for the District of Columbia Circuit upheld the denial of the providers' bad debt claims associated with dual eligible beneficiaries. Grossmont...more

9/5/2015 - Appeals Bad Debt CMS Co-Insurance Payments Deductibles Dual Beneficiaries Filing Deadlines Hospitals Medi-Cal Medicaid Medicare Provider Reimbursement Manual

CMS's "At a Collection Agency" Bad Debt Policy - Confusion Continues

As we reported in previous Payment Matters articles, the United States District Court for the District of Columbia has issued inconsistent opinions regarding Medicare's policy not to allow bad debt when that bad debt is still...more

8/26/2015 - Appeals Bad Debt CMS Collection Agencies Health Care Providers Hospitals Medicare Split of Authority

Supreme Court: Providers' Appeal Period Not Extended by Doctrine of Equitable Tolling

Under the Medicare statute and implementing regulation, providers have 180 days from the issuance of a Notice of Program Reimbursement (NPR) in which to file an appeal to the Provider Reimbursement Review Board (PRRB). This...more

2/7/2013 - Appeals Equitable Tolling Medicare NPR Provider Reimbursement Review Board

Court Rules That Medicare DSH Statute Means What It Says

In recent times, the provider community has enjoyed success in challenging the Secretary’s interpretation of the Medicare disproportionate share hospital (DSH) adjustment provisions and what, the providers have maintained,...more

1/25/2013 - Appeals Disproportionate Share Adjustments Hospitals Medicare Retroactive Application

Providers Again Win in Medicare Disproportionate Share Adjustment Challenge

In a 2011 decision, Northeast Hospital Corp. v. Sebelius, 657 F. 3d 1 (D.C. Cir. 2011), the United States Court of Appeals for the District of Columbia Circuit ruled for the providers in a challenge to the Secretary’s...more

12/13/2012 - Appeals Disproportionate Share Adjustments Medicare

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