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

CMS Announces New Cost Reporting Procedures to Address DSH Uncompensated Care Payments

In the fiscal year 2014 Inpatient Prospective Payment System (IPPS) rule (the “final rule”), CMS explained the new disproportionate share hospital (DSH) payment methodology that took effect this October 1. As we reported in...more

10/18/2013 - CMS DSH Hospitals Patient Prospective Payment System

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 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 Places Limits on Secretary's "No Reopening" Arguments

CMS has often argued that “base year” determinations cannot be revisited once the three-year reopening period has closed. Now, a recent decision from the U.S. Court of Appeals for the District of Columbia Circuit places those...more

3/31/2013 - CMS FTEs Hospitals Kaiser v Sebelius Reimbursements

CMS Revises Part B Billing Policy for Unnecessary Inpatient Admissions

For many years, CMS policy has been that, if an inpatient admission was denied for medical necessity reasons, the hospital could bill under Part B for only a limited set of services that, significantly, did not include...more

3/29/2013 - Administrative Appeals ALJ CMS Hospitals Medicare Medicare Part B

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

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