News & Analysis as of

Centers for Medicare & Medicaid Services Health Care Providers

Deemed Providers Beware: IPPS Rule Proposes Publicizing Accreditation Survey Results

by Baker Ober Health Law on

The veil of secrecy may soon be lifted from the reports of accreditation organizations like The Joint Commission if a proposal in the April 28, 2017 Inpatient Prospective Payment System (IPPS) Proposed Rule is finalized. As...more

Revocation of Enrollment in the Medicare Program- A Powerful Weapon in Medicare’s Arsenal

by Burr & Forman on

In 2014, CMS issued a final rule related to 42 CFR 424.535, which gave CMS expanded authority to impose penalties on providers. Although the rule is several years old, the first version published in 2006, the rule has been...more

GAO: CMS, MACs Should Bolster Provider Education to Cut Improper Medicare Payments

by Reed Smith on

In 2016, an estimated $41.1 billion in improper Medicare fee-for-services payments were made to providers. The Centers for Medicare & Medicaid Services (CMS) believes that provider education plays an important role in...more

Health Care Provider Insights - Introductory Edition

by Wilson Elser on

Welcome to the introductory edition of Health Care Provider Insights. We are practice management consultants, providing legal and business management advice and assistance to physicians and dentists (health care...more

Center For Medicare And Medicaid Services Proposes Delay Of Implementation Of New Home Health Agency Rules

by Roetzel & Andress on

On January 13, 2017, the Center for Medicare and Medicaid Services (CMS) issued a final rule relating to a series of changes for conditions to participation in Medicare and Medicaid by home health agencies (HHAs). At the time...more

Ten Things Investors Need to Know About Value-Based Healthcare

by Ropes & Gray LLP on

This article highlights key business and legal issues related to value-based healthcare for investors considering opportunities in the healthcare industry. 1. Value-Based Arrangements Are Here to Stay Value-based...more

The Financial Impact of MACRA – Uncertainty Reigns in a Recent Rand Corporation Study

With all the talk of the Affordable Care Act’s uncertain future, it is easy to forget about the Medicare Access and CHIP Reauthorization Act (“MACRA”), a bipartisan law passed by Congress in 2015 to change the way physicians...more

Stark Law: What Providers Should Know About New CMS Form

by Polsinelli on

The Centers for Medicare and Medicaid Services (CMS) has finalized Form CMS-10328 (the SRDP Form), a new OMB-approved information collection instrument that must be used by providers and suppliers utilizing the Stark Law...more

CMS Proposes FY 2018 Update to Medicare Hospice Payment Rules; Solicits Ideas for Hospice Program Improvements

by Reed Smith on

CMS has published a proposed rule to establish fiscal year (FY) 2018 Medicare hospice reimbursement rates, update hospice quality programs, and request public input on ways to improve the Medicare hospice program. The...more

CMS Issues New SRDP Forms

by Dorsey & Whitney LLP on

The Centers for Medicare and Medicaid Services (“CMS”) issued new Self-Referral Disclosure Protocol (“SRDP”) forms, and, beginning June 1, 2017, these SRDP forms will be mandatory for those parties submitting voluntary...more

CMS request for information presents rare opportunity for medicare stakeholder engagement

by Hogan Lovells on

On 14 April 2017, the Centers for Medicare & Medicaid Services (CMS) published the fiscal year (FY) 2018 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective...more

CMS Requests “National Conversation” About Improving Medicare

by Fox Rothschild LLP on

As many people are discussing methods to improve healthcare, the Centers for Medicare & Medicaid Services (CMS) is giving stakeholders an opportunity to send in their thoughts on this topic. In CMS’s April 14, 2017 proposed...more

CMS mandates new Stark Self-Referral Disclosure Protocol form

by Thompson Coburn LLP on

The Centers for Medicare and Medicaid Services’ (CMS) Self-Referral Disclosure Protocol (SRDP) outlines a process for providers to disclose to CMS potential or actual violations of the Stark law...more

Leasing to Health Care Tenants: What You Need to Know

by Pepper Hamilton LLP on

Commercial office building landlords frequently find themselves leasing to health care provider tenants. A landlord may not consider doctor’s offices or diagnostic labs as specialty uses, but there are several lease...more

CMS Finalizes New SRDP Disclosure Form and Process

by Baker Ober Health Law on

Parties disclosing actual or potential violations of the Stark law will use a new series of forms under CMS's Voluntary Self-Referral Disclosure Protocol (SRDP) process as of June 1, 2017. According to CMS, the new forms...more

Calling for Ideas—CMS Releases Final 2018 Medicare Advantage and Part D Rate Announcement and Call Letter

by Hogan Lovells on

On 3 April 2017, the Centers for Medicare & Medicaid Services (CMS) released its final Medicare Advantage (MA) and Part D Rate Announcement and Call Letter (Call Letter) for calendar year 2018. The Call Letter is part of...more

CMS Revises the Self-Referral Disclosure Protocol Requiring the Use of Prescribed Forms for Disclosure of Stark Law Violations

by McDermott Will & Emery on

The Centers for Medicare and Medicaid Services (CMS) recently posted revisions to the Voluntary Self-Referral Disclosure Protocol (SRDP). In an attempt to streamline the self-disclosure process, CMS requires the use of new...more

CMS Considering 6-Month Delay of Obama Administration Home Health COP Rule

by Reed Smith on

As previously reported, in January 2017 the Obama Administration finalized major changes to the conditions of participation (CoPs) that home health agencies (HHAs) must meet to participate in Medicare and Medicaid. The rule...more

CMS Encourages Providers/Suppliers Not To Put Off Emergency Preparedness Training Exercises; Educational Call Scheduled for April...

by Reed Smith on

CMS is reminding Medicare- and Medicaid-participating providers and suppliers that they will be expected to comply with training and testing requirements included in a September 2016 emergency preparedness final rule by...more

CMS Delays Implementation of New Payment Models (Again)

On March 21, 2017, the Centers for Medicare and Medicaid Services (“CMS”) published an interim final rule (“Interim Final Rule”) delaying (i) the effective date of several new Medicare payment models developed by the CMS...more

Long-Term Care Facilities Subject to New Medicare Requirements for Participation Must Comply with Staffing, Training, and...

by Arnall Golden Gregory LLP on

On October 4, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule which represents the most sweeping changes in twenty-five years regarding the requirements for participation for long-term care (LTC)...more

Healthcare Law Update: March 2017

by Holland & Knight LLP on

Enforcement - OIG Issues Advisory Opinion Allowing Free or Reduced-Cost Lodging and Meals - On March 3, 2017, the U.S. Department of Health and Human Services' (HHS) Office of Inspector General (OIG) issued...more

Third-Party Payment of Premiums: Controversy and HHS Guidance

Since the passage of the Affordable Care Act (ACA), the payment of healthcare premiums by third parties has been the subject of controversy. As Congress develops its plan to repeal and replace the ACA, it is uncertain how...more

Medicare’s Pre-Claim Review Demonstration Project to Begin in Florida

by Arnall Golden Gregory LLP on

In August 2016, the Centers for Medicare & Medicaid Services (CMS) initiated a three-year Pre-Claim Review Demonstration for home health agencies (HHA) in Illinois, with plans to expand the demonstration shortly afterwards to...more

The Transition to Value-Based Health Care: A View from Washington of President Trump’s First 60 Days

by Ropes & Gray LLP on

“A View from Washington of President Trump’s First 60 Days,” the inaugural segment of our value-based health care teleconference series, was hosted by Thomas Bulleit, who heads the Ropes & Gray health care practice in the...more

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