On August 30, 2022, the Centers for Medicare & Medicaid Services (CMS) announced that the Medicare Shared Savings Program (MSSP) had saved the Medicare program $1.66 billion in 2021 as compared to spending targets, while...more
The Centers for Medicare and Medicaid Services (CMS), as part of 2023 Physician Fee Schedule proposed rule, has proposed significant revisions to the Medicare Shared Savings Program (MSSP). The revisions to the MSSP in the...more
Today's post is the last in our series on the 10-year anniversary of the Affordable Care Act (ACA). While the Congress that passed the ACA recognized that health care delivery reform was necessary, the law included few...more
The U.S. healthcare industry remains at a crossroads. The healthcare reform legislation passed under President Barack Obama in 2010, officially called the Patient Protection and Affordable Care Act (ACA) but widely referred...more
As K&L Gates begins its third season of Triage: Rapid Legal Lessons for Busy Health Care Professionals, Hilary Bowman previews several topics that the health care practice group anticipates will have a significant impact on...more
The Centers for Medicare & Medicaid Services (CMS) published a proposed rule on August 17, 2018, that would make sweeping changes to the Medicare Shared Savings Program (MSSP), a federal program that incentivizes integrated...more
On December 20, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (the Final Rule) which includes three new mandatory episode-based payment programs for cardiac care, as well as the expansion of the...more
On November 2, 2016, the Centers for Medicare and Medicaid Services (CMS), released the 2017 Medicare Physician Fee Schedule (MPFS) final rule, which finalized a number of new policies designed to improve Medicare payment for...more
McCarter & English, LLP’s Health Care Group presents Issue 13 of the Health Law Insights, which discusses the latest legal issues in the health care industry. - Failure to Update Business Associate Agreement Results in...more
In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”)....more
Since the Affordable Care Act was enacted, many providers have been shifting away from traditional fee-for-service, volume-based reimbursement models to payment mechanisms that take a data-driven approach to managing patients...more
The American Hospital Association (AHA) has written to John Koskinen, Commissioner of the Internal Revenue Service (IRS), and Mark Mazur, Assistant Secretary for Tax Policy at the Treasury Department, raising concerns about...more
On April 8, 2016, the IRS released private letter ruling 201615022 denying tax-exempt section 501(c)(3) status to a nonprofit accountable care organization (“ACO”) that did not participate in the Medicare Shared Savings...more
The IRS recently released a ruling, Private Letter Ruling (“PLR”) 201615022, denying Section 501(c)(3) tax-exempt status to a “commercial” accountable care organization (“ACO”). This is the IRS’ first published guidance...more
Better Late Than Never: CMS Provides Much-Needed Clarity on the 60-Day Overpayment Refund Requirements - On February 12, 2016, the Centers for Medicare & Medicaid Services (CMS) issued the long-awaited final rule (Final...more
Final ACO Fraud Waiver Under OMB Review – The White House Office of Management and Budget (OMB) reported on September 9, 2015, that it began its review of the final rule (CMS-1439-F; RIN 0938-AR30), titled “Medicare Shared...more
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
Examining Fee Splitting Statutes in the Context of Value-Based Healthcare - Editor’s note: One of the goals of the Affordable Care Act (ACA) is to align incentives among provider communities and their patients and...more
An Overview of the Medicare Shared Savings Program/Accountable Care Organization Final Rules - The Centers for Medicare and Medicaid Services (CMS) recently released a final rule (Final Rule) that makes changes to the...more
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule (Final Rule) that makes changes to the Medicare Shared Savings Program (MSSP). The Affordable Care Act (ACA) created the MSSP as one of...more
In This Issue: - CMS Finalizes ACO Program Rules; Scales Alternative Payment Model - Implementation of the Affordable Care Act - Federal Regulatory Initiatives - Congressional Initiatives - Other...more
While one part of the Affordable Care Act, exchange subsidies, hangs in the balance with the Supreme Court’s upcoming decision in King v Burwell, CMS is moving forward aggressively with the evolution of a less controversial...more
As we look into our crystal balls, we do not expect a lot of new issues in 2015. Rather, we believe that most of the significant issues will be a continuation of issues that arose in 2014 or earlier. ...more
Each year brings significant changes and challenges in the laws governing the health care industry, and 2014 proved to be no exception. What the year may have lacked in the high drama that accompanies comprehensive health...more
In This Issue: - Top News ..Congress Passes Omnibus Spending Package ..HRSA Cancels Plan for 340B ‘Mega Reg’; Congress Weighs Options ..Supreme Court to Hear Challenge to ACA Subsidies ...more