The U.S. Department of Health and Human Services (HHS) has just unveiled a proposed rule designed to penalize health care providers engaging in information blocking. Information blocking is a practice where health care...more
This Client Alert serves as the second in a three-part series in which we describe and analyze the rules proposed by the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) as part of its...more
Key Points - On October 17, 2019, the OIG proposed rules to add safe harbor protections for coordinated care and associated value-based arrangements. - The OIG proposed several new safe harbors: value-based...more
On July 29, 2019, CMS released the Calendar Year (CY) 2020 Physician Fee Schedule (PFS) proposed rule (the Proposed Rule). The Proposed Rule updates payment policies, payment rates, and quality provisions for services...more
The Situation: On October 8, 2018, California's Office of Administrative Law ("OAL") rejected a regulation that the Department of Managed Health Care ("DMHC") proposed. The regulation would require accountable care...more
The U.S. Department of Health and Human Services (HHS) has launched its “Regulatory Sprint to Coordinated Care” to accelerate the healthcare system’s transformation to a value-based system rewarding coordinated care. This...more
August 24, 2018 marked a busy day for the U.S. Department of Health & Human Services' (HHS) self-designated "Regulatory Sprint to Coordinated Care," an initiative aimed at dismantling the regulatory barriers to providers...more
Regulation - CMS Contemplating Telemedicine Changes - The Centers for Medicare & Medicaid Services (CMS) recently published what it described as a "major proposed rule" that covers a number of topics that could have...more
The Centers for Medicare & Medicaid Services (“CMS”) recently proposed a major redesign of its Medicare Shared Savings Program (“MSSP”) under a new plan it calls “Pathways to Success.” In this Part II of the two-part series...more
In an August 9, 2018 proposed rule, the Centers for Medicare & Medicaid Services (CMS) seeks to redirect the Medicare Shared Savings Program (MSSP) on so-called “Pathways to Success.”...more
On Monday, the Department of Health and Human Services (HHS) Office of the Inspector General (OIG) published a wide-ranging request for information (RFI) seeking ideas on how it might add or modify safe harbors to the...more
On August 9, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would redesign the Medicare Shared Savings Program (MSSP). The proposed changes would accelerate the risks associated with...more
On August 9, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule to overhaul the Medicare Shared Savings Program (MSSP). The proposal, titled “Pathways to Success,” would make significant changes...more
On Thursday, August 9, 2018, the Centers for Medicare & Medicaid Services (“CMS”) published a Proposed Rule (the “Proposed Rule”) regarding the Medicare Shared Savings Program (“MSSP”) for Accountable Care Organizations...more
On Aug. 9, 2018, Centers for Medicare and Medicaid Services (CMS) released a proposed rule that would update the Medicare Shared Savings Program (MSSP). Called "Pathways to Success," the proposal significantly alters the...more
On Oct. 14, the Centers for Medicare & Medicaid Services (CMS) published a final rule with comment period implementing the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The nearly 2,400 pages of...more
The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule modifying the Medicare Shared Savings Program (MSSP) regulations (the “Rule”). Among other changes, the Rule proposes (a) to modify the...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
Solutions and opportunities may be on the horizon for post-acute providers (“PAPs”) and hospitals participating (or thinking of participating) in ACOs that have reservations about taking on additional downside cost risk...more
On Dec. 1st, the Centers for Medicare and Medicaid Services released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). The voluminous proposal covers a...more