FQHC

News & Analysis as of

Manatt on Health Reform: Weekly Highlights - May 2016

CMS encourages access to Medicaid for eligible inmates transitioning to their communities, while New York seeks to extend Medicaid coverage to eligible inmates in the days prior to release; Pennsylvania seeks to shift $6...more

New Stark Law Exception Breathes Life into Primary Care, Especially in Underserved Areas

With the recent and significant shortages of primary care providers, the Centers for Medicare & Medicaid Services (“CMS”) recently created a rather important exception to the Stark Law as a means to expand access to primary...more

A&B Healthcare Week in Review

I. REGULATIONS, NOTICES, & GUIDANCE - On February 24, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a guidance entitled, “Special Enrollment Confirmation Process” that will enhance program integrity...more

Alert: 340B Self-Audits: The Best Defense Is A Good Defense

Federally qualified health centers (FQHCs) participating in the 340B Drug Pricing Program (the “340B Program”) are subject to audits by Health Resources and Services Administration (HRSA) and the drug manufacturers who...more

CMS Updates Manual Provisions for Rural Health Clinics and Federally Qualified Health Centers

On December 31, 2015, CMS updated Chapter 9 of the Medicare Claims Processing Manual and Chapter 13 of the Medicare Benefit Policy Manual addressing payment and certification of Rural Health Clinics (RHCs) and Federally...more

Health Law Pulse - January 2016

CHANGES TO STARK LAW, NEW ADVANCE CARE PAYMENTS INCLUDED IN 2016 PHYSICIAN FEE SCHEDULE - The Centers for Medicare & Medicaid Services (CMS) recently published a final rule (Final Rule) regarding physician payment...more

New Stark Law Exception Allows Hospitals, FQHCs and RHCs to Assist Physicians with Engaging Non-Physician Practitioners

The Centers for Medicare & Medicaid Services (CMS) recently released a new exception to the Physician Self-Referral Law (the “Stark Law”) intended to expand access to primary care and mental health services (the “NPP...more

CMS finalizes significant Stark Law rulemaking

In July of this year, the US Department of Health & Human Services (HHS), Centers for Medicare & Medicaid Services (CMS) proposed significant changes to the regulations implementing the federal physician self referral law...more

Alert: Proposed 340B Drug Pricing Program Omnibus Guidance - Defines "Eligible Patient"

On August 28, 2015, the Health Resources and Services Administration (“HRSA”) published the proposed 340B Drug Pricing Program Omnibus Guidance (“Omnibus Guidance”) which is intended to clarify for covered entities, such as...more

Baker Donelson Comments on CMS's Proposed Changes to the Stark Regulations - September 2015

The law firm of Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C., sincerely appreciates the opportunity to comment upon the proposed clarifications and changes to the Stark regulations issued by the Centers and Medicare...more

340B Guidance: Eight Key Points Covered Entities Should Consider

On August 27, 2015, the Health Resources and Services Administration (HRSA), an agency of the U.S. Department of Health and Human Services (HHS), released the 340B Drug Pricing Program Omnibus Guidance (Guidance). Referred to...more

Proposed 2016 Medicare Physician Fee Schedule Includes Changes to Stark Regulations

The Centers for Medicare & Medicaid Services ("CMS") recently released the proposed 2016 Medicare Physician Fee Schedule (the "Proposed Rule"), which includes a number of proposed revisions to the regulations under the...more

Health Law Pulse - August 2015

The Office of the Inspector General (OIG) recently issued a favorable advisory opinion (Advisory Opinion) to a nonprofit health system (System) and a nonprofit psychiatric hospital (Center) regarding a proposal whereby the...more

Connecticut Enacts Health Care Legislation in June Special Session

On June 29 and 30, 2015, the Connecticut General Assembly conducted a special legislative session following the close of the 2015 regular session. Among other things, the General Assembly passed a bill to implement the state...more

The Implications of CMS' Proposed Stark Law Regulations

On July 8, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released proposed regulations “to reduce burden and to facilitate compliance” under the physician self-referral law known as the Stark Law. See 80 Fed....more

CMS Proposes Stark Law Amendments, Requests Comments on Whether Stark Law Is Barrier to Health Care Reform

On July 8, 2015, the Centers for Medicare & Medicaid Services (CMS) published a notice of proposed rulemaking to amend its regulations implementing and interpreting the Stark Law (the Proposed Rule). 80 Fed. Reg. 41,686,...more

Proposed Rule Aims to Refine Stark Regulations and Clarify “Incident To”

On July 15, 2015, the Centers for Medicare and Medicaid Services (CMS) published the calendar year (CY) 2016 Physician Fee Schedule Proposed Rule. In addition to updating several traditional Part B payment policies, the...more

Potential Stark Changes Ahead

On July 15, 2015, the Centers for Medicare and Medicaid Services (“CMS”) published proposed regulations governing policies and payments made under the Physician Fee Schedule for calendar year 2016 (the “Proposed Rule”). In...more

Stark Regulations: Proposed Physician Recruitment Provisions

Assistance to Employ a Non-Physician Practitioner (NPP) - Currently under the Stark law, the physician recruitment exception (42 C.F.R. § 411.357(e)) permits hospitals, Federally Qualified Health Centers (FQHCs) and...more

CMS Issues CY 2016 Medicare Physician Fee Schedule Proposed Rule

On July 8, 2015, CMS issued its annual proposed rule outlining payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) for CY 2016. In the proposed rule,...more

Congress Wows With Medicare Telehealth Parity Act of 2015, But Will It Succeed?

Rep. Mike Thompson (D-CA) and co-sponsors Rep. Gregg Harper (R-MS), Rep. Diane Black (R-TN), and Rep. Peter Welch (D-VT) announced, on July 7, 2015, the introduction of the Medicare Telehealth Parity Act of 2015,...more

Breaking News: Top 10 Ways the Proposed Rule Impacts Stark Law

With surprisingly little fanfare, the CY 2016 Physician Fee Schedule (the "Proposed Rule") released on July 8, 2015 proposes to add and amend several exceptions to the Physician Self-Referral Statute, commonly known as the...more

Beneficiary Assignment Under the MSSP Final Rule

This is the fourth post in Health Care Law Today’s series on the final rule. This post addresses how CMS assigns beneficiaries to an ACO participating in the MSSP. In the MSSP ACO Final Rule, CMS finalized new...more

CMS Releases 2016 Physician Fee Schedule

Major changes to Stark law are ahead, including new exceptions for timeshare arrangements and employment of NPPs. The Centers for Medicare & Medicaid Services (CMS) released a proposed rule on July 8 for the 2016...more

CMS Releases New Guidance on Quality Reporting Payment Adjustments for RHCs, FQHCs, and CAHs

On March 6, 2015, CMS released an MLN Matters article (#SE1508), updating guidance on the 2015 payment adjustments for Rural Health Clinics (RHCs), Federally Qualified Health Centers (FQHCs), and Critical Access Hospitals...more

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