Thomas W. Coons

Thomas W. Coons

Ober|Kaler

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"Incident To" Personnel and Credentials: CMS's New Teeth to Address an Old Problem

Medicare’s “incident to” provision found at 42 U.S.C. § 1395x(s)(2)(A) addresses coverage of services and supplies furnished “incident to a physician’s professional service,” principally in a physician’s office or clinic....more

1/24/2014 - CMS Compliance Healthcare Hospitals IPPS Medicare

SGR-Driven Payment Reduction Postponed Again

As part of the Balanced Budget Act of 1997 (BBA), Congress enacted a number of payment reforms designed to curb the growth of expenditures under Medicare Part B. One of the more notable of those provisions was the Sustainable...more

1/8/2014 - CMS Healthcare Healthcare Professionals Medicare Medicare Part B Physician SGR Formula Physicians

IPPS Final Rule: CMS Addresses Allina Decision and Addresses New Medicare DSH Payment Calculations

In the fiscal year 2014 Inpatient Prospective Payment System (IPPS) rule published in the Federal Register on August 19, 2013, CMS took two steps of note regarding the Medicare disproportionate share hospital (DSH)...more

8/28/2013 - CMS Disproportionate Share Adjustments Healthcare Hospitals Medical Expenses Medicare Payment Plans

CMS's Use of Contractors to Determine "Sustained or High Level of Payment Errors" Upheld

In a decision handed down on July 23, 2013, the United States Court of Appeals for the D.C. Circuit upheld the use by CMS of outside contractors to determine whether a home health agency’s reimbursement claims had exhibited a...more

8/9/2013 - CMS Contractors Healthcare Home Health Care Medicare Overpayment Reimbursements

CMS Proposes Significant Changes and Clarifications in OPPS Proposed Rule

In its OPPS proposed rule published July 19, 2013 [PDF], at Fed. Reg. 43534-43707, CMS proposed significant changes and clarifications to its current policy. Among the most notable changes are the four discussed below...more

7/24/2013 - CMS Healthcare Hospitals Medicaid Medicare Physicians

Court of Appeals Hands Down Significant DSH Ruling

As we reported in a Payment Matters article dated February 16, 2012, early last year the United States District Court for the District of Columbia handed providers a significant victory in Catholic Health Initiatives-Iowa v....more

6/28/2013 - CMS DSH Healthcare Medicaid Medicare

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