Centers for Medicare & Medicaid Services Hospitals

News & Analysis as of

Reimbursement Changes for Hospital Off-Campus Provider-Based Departments

Off-campus provider-based departments (PBDs) of hospitals face changes in reimbursement beginning Jan. 1, 2017, the effective date of the Centers for Medicare & Medicaid Services (CMS) outpatient prospective payment system...more

CMS Finalizes Testing of New Episode Payment Models and MSSP Track 1+ ACO

On January 3, 2017, CMS published a final rule addressing three care coordination models: - Cardiac care: CMS added two new cardiac care episode payment models (“EPMs”) for items and services furnished to patients...more

Urban hospitals that established GME caps after 1996: Be careful with this compliance issue

If a teaching hospital meets certain regulatory requirements, the hospital is generally permitted to loan its cap slots to other hospitals through a Medicare GME affiliated group agreement. (See Sharing FTE Caps: Threshold...more

CMS Clarifies the Application Processes for the Mid-Build Exception under the 21st Century Cures Act and for Relocation Exception...

CMS has issued guidance documents addressing how hospitals can (1) qualify an off-campus provider-based department (PBD) for the “mid-build” exception set forth in the 21st Century Cures Act and (2) request from their CMS...more

CMS Corrects Final 2017 OPPS/ASC Rule, Results in Slight Payment Increase

CMS has published a notice correcting technical errors in its November 14, 2016 final rule with comment period updating the Medicare hospital outpatient prospective payment system (OPPS) and ambulatory surgical center payment...more

CMS Issues Time-Sensitive Instructions for Provider-Based Clinics That Have Relocated

Hospitals that have relocated a provider-based clinic after the enactment of the Bipartisan Budget Act must take action now. Centers for Medicare & Medicaid Services (CMS) recently released guidance on extraordinary...more

A Condition of Participation for Medicare Providers in 2017

This year, Medicare providers and suppliers — including hospitals, ambulatory surgical centers (ASCs) and end-stage renal disease (ESRD) facilities — will need to develop emergency preparedness plans for both natural and...more

HHS OIG Issues Report on Medicare’s 2-Midnight Rule

On December 19, 2016, the HHS OIG issued a report on Medicare’s 2-midnight rule titled “Vulnerabilities Remain Under Medicare 2-Midnight Hospital Policy.” The report reviews data from 2013 and 2014 and reaches several...more

Final Rule Implements Quality Payment Program under MACRA

If you are a physician, mid-level provider, or work with those providers, then you have been bombarded with new acronyms for new programs and promises to remove older acronyms from your Medicare vocabulary. Medicare...more

OIG Issues Report on Medicare’s ‘2-Midnight Hospital Rule’

On December 19, 2016, the US Department of Health and Human Services Office of Inspector General (OIG) posted a report examining the Centers for Medicare & Medicaid Services’ (CMS’s) “2-Midnight Rule.” The OIG concluded that...more

CMS Issues Final Rule for New Cardiac, Orthopedic Bundled Payment Models

On December 20, 2016, CMS issued its final rule implementing three new Medicare Parts A and B episode payment models for patients admitted for treatment for heart attack, bypass surgery, or hip/femur fracture under its...more

21st Century Cures Act Provides Some Welcome Relief

The 21st Century Cures Act (the “Cures Act”) (Pub. L. No. 114-255), which was signed into law by President Obama on December 13, 2016, includes a number of important health care provisions, and several address the...more

CMS Publishes the Medicare Outpatient Observation Notice Form and Instructions

On December 8, 2016, CMS published the final version of the Medicare Outpatient Observation Notice (MOON) that hospitals and critical access hospitals (referred collectively as "hospitals" herein) must use to provide notice...more

CMS Releases Medicare Outpatient Observation Notice Form

On December 8, 2016, the Centers for Medicare and Medicaid Services (CMS) published the Medicare Outpatient Observation Notice (MOON), which educates Medicare beneficiaries on the effect of outpatient status, particularly as...more

HHS-OIG reports on impact and vulnerabilities of Medicare's Two-Midnight Rule

On December 19, 2016, the US Department of Health and Human Services, Office of Inspector General (HHS-OIG) issued a report, "Vulnerabilities Remain Under Medicare 2-Midnight Hospital Policy" (OEI-02-15-00020). The report is...more

Also In The News - Health Headlines - December 2016

CMS Releases the Finalized Medicare Outpatient Observation Notice Form – On December 9, 2016, CMS released the final Medicare Outpatient Observation Notice (MOON) form. The MOON form is a standardized form developed by CMS...more

21st Century Cures Act: Who Does the “Mid-Build” Exception Help?

The exception helps a number of hospitals with their provider-based sites that had been under construction in November 2015, but not as many as may initially appear. Read on if you are interested in understanding the...more

CMS Releases Standardized Hospital Medicare Outpatient Observation Notice Form

Hospitals are facing a March 8, 2017 deadline to begin using the new Medicare Outpatient Observation Notice (MOON) to inform Medicare beneficiaries when they are outpatients receiving observation services and not inpatients...more

CMS Final Rule and 21st Century Cures Act Include Good and Bad News for Provider-Based Sites

CMS recently published its final outpatient prospective payment system (OPPS) rule, which includes its new policies governing payment related to services furnished at off-campus provider-based departments (OPBDs). 81 Fed....more

Senate Finance Committee Releases Report on Concurrent and Overlapping Surgeries

On December 6, 2016, Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) issued a Committee staff report detailing concurrent and overlapping surgery practices. The report also offers...more

CMS Reminds Providers to Identify Off-Campus Provider-Based Departments on Enrollment Forms

In connection with CMS’s implementation of Section 603 of the Bipartisan Budget Act of 2015 (BBA15), which directs CMS to no longer pay hospitals the full OPPS rate for services furnished in non-excepted off-campus...more

2016 Health IT Leadership Summit Insights

On December 7, 2016, lawyers from Arnall Golden Gregory LLP’s Healthcare Technology team attended the annual Health IT Leadership Summit. While there, we noted several overarching themes. At the forefront were the topics of...more

2016 Health Care Year in Review

Since I began writing this year-end review in 2013, there have been some common themes – a shift to pay for quality and away from fee-for service, much of which has been brought about by the Affordable Care Act (ACA): efforts...more

CMS Issues Final Rule on Off-Campus Hospital Department Reimbursement

As of January 1, 2017, hospitals will receive lower Medicare reimbursement for items and services provided at certain off-campus provider-based facilities. This Alert provides an overview of the new reimbursement framework...more

OPPS Provider-Based Final Rule — A More Practical Approach From CMS

CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”). CMS revealed the changes on November 1...more

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