Effective for hospital inpatient admissions on or after October 1, 2018, CMS has removed the requirement that a signed physician order must be present in the medical record to establish inpatient coverage. While this guidance...more
On May 14, 2018, the U.S. Attorney’s Office for the Southern District of Texas announced that Memorial Hermann Health System (MHHS) will pay $1,929,071.38 to resolve allegations that it improperly billed government healthcare...more
On April 24, 2018, the Centers for Medicare and Medicaid Services (CMS) published the 2019 Medicare Inpatient Prospective Payment System proposed rule (2019 Proposed IPPS Rule), which contains a number of proposals designed...more
On April 24, 2018, the Centers for Medicare & Medicaid Services (CMS) released the Fiscal Year (FY) 2019 Inpatient Prospective Payment System (IPPS) Proposed Rule (CMS-1694-P). Among other changes, CMS proposes eliminating...more
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
Earlier this month, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (Final Rule) modifying the Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective...more
On August 2, 2016, CMS released a final rule (Final Rule) with updates to the Hospital Inpatient Prospective Payment System (Hospital IPPS) and Long-Term Care Hospital Prospective Payment System (LTCH PPS) affecting...more
Medicare and Medicaid Services (CMS) on August 19, 2013, the two-midnight rule provided that an inpatient admission generally would only be payable under Medicare Part A if: (1) the admitting practitioner had an expectation,...more
CMS recently issued a proposed rule updating fiscal year (FY) 2017 Medicare payment policies and rates under the Medicare inpatient prospective payment system (IPPS) and the long-term care hospital (LTCH) prospective payment...more
In the FY 2017 IPPS Proposed Rule, CMS announced that it would reverse the 0.2 percent IPPS rate cut that was imposed in FY 2014 (and re-adopted in subsequent years) related to the Two Midnight Rule and increase the...more
- CMS Adopts Change to Benchmark and Shift in Enforcement - CMS Explains Reasoning Behind 0.2% Payment Reduction CMS has published discussions of the 2-midnight rule in two recent Federal Register publications. In the...more
On December 1, 2015 CMS published a Notice in the Federal Register that provides additional information as to the methodology the agency used to arrive at the 0.2 percent rate reduction associated with the implementation of...more
On October 30, 2015, CMS issued its final rule with comment period (Final Rule) for the Medicare hospital outpatient prospective payment system (OPPS) and the Medicare ambulatory surgical center (ASC) payment system for...more
On October 30, 2015, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2016 Outpatient Prospective Payment System Final Rule (2016 OPPS Final Rule). In the 2016 OPPS Final Rule, CMS finalizes...more
On September 21, 2015, the United States District Court for the District of Columbia ruled that the Secretary of the U.S. Department of Health and Human Services (HHS) failed to provide a meaningful opportunity to comment on...more
On July 8, 2015, the Centers for Medicare and Medicaid Services (“CMS”) released a Proposed Rule regarding the 2016 Hospital Outpatient Prospective Payment System (“OPPS”). The Proposed Rule, in addition to proposing updates...more
On July 31, 2015, CMS issued its final rule to update the fiscal year (FY) 2016 Medicare payment policies and rates under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective...more
In the 2016 inpatient prospective payment system (IPPS) proposed rule, CMS promised to provide further guidance on the controversial "two midnight" rule in the forthcoming outpatient prospective payment system (OPPS) rule....more
On April 17, 2015, CMS released a copy of its proposed changes and updates to the Medicare inpatient prospective payment system (IPPS) for fiscal year 2016. The official version appears in the April 30th Federal Register, and...more
On August 2, 2013, the Centers for Medicare and Medicaid Services (“CMS”) released the final rule for the 2014 Medicare Inpatient Prospective Payment System (“IPPS”), effective October 1, 2013.[1] Introduced in the IPPS...more
On June 30, 2014, King & Spalding filed comments in response to Medicare’s proposed IPPS rule for Fiscal Year (FY) 2015 on behalf of more than 200 hospitals it represents in a federal court challenge to the FY 2014 Two...more
On March 25, 2014, King & Spalding filed a complaint in the United States District Court for the District of Columbia challenging CMS’s 0.2 percent reduction to FY 2014 IPPS payment rates associated with the two-midnight...more