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Hospitals › Reconciliation

Baker Donelson

Court Upholds Procedural Validity of HHS's Outlier Reconciliation Instructions

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On December 26, 2017, the United States Court of Appeals for the District of Columbia Circuit upheld the procedural validity of 2010 manual instructions setting out the criteria by which Medicare outlier payments might be...more

Baker Donelson

What's Next Now that Mandatory EPM and Cardiac Rehabilitation Payment Models Have Been Terminated?

Baker Donelson on

CMS released its Final Rule canceling the Episode Payment Model (EPM) and Cardiac Rehabilitation Incentive Payment Model (CR Incentive Payment Model). This was an expected result following August's proposed rule to cancel...more

King & Spalding

In Targeting Outlier Payment Reconciliation, OIG Calls for an Aggressive Reading of CMS Reopening Regulations

King & Spalding on

The HHS OIG recently published a report detailing CMS’s and Medicare Administrative Contractor’s (“MACs’”) ongoing issues in the outlier payment reconciliation process. A previous 2012 review identified 465 cost reports that...more

Baker Donelson

Outliers: CMS Explains its Reasoning for FY2004 Fixed Loss Threshold Calculation

Baker Donelson on

In accordance with the order issued by the D.C. Circuit in District Hospital Partners, LP v. Burwell and related cases, on January 22, CMS issued an explanation of the methodology it used to calculate the fixed-loss threshold...more

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