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Off-Campus Departments

McDermott+

Site Neutral Payment Considerations: Site-of-Service Patterns Vary by Geography

McDermott+ on

Site neutral payment proposals are currently a key topic among policymakers. This +Insight explores how Medicare fee-for-service (FFS) site-of-service patterns vary across states and metropolitan statistical areas (MSAs). Our...more

McGuireWoods Consulting

Medicare Site-Neutral Payments Included in House Energy and Commerce Health Subcommittee Markup

On May 17, the House Energy and Commerce Committee Health Subcommittee held a markup of 17 healthcare bills. In particular, the subcommittee advanced legislation that would implement site-neutral payments under Medicare for...more

Proskauer - Health Care Law Brief

The University of Miami to Pay $22 Million to Settle Medicare False Claims Act Allegations

The U.S. Department of Justice (the “DOJ”) recently settled whistleblower False Claims Act (“FCA”) allegations against The University of Miami (“UMiami”) for $22 million, which resolves claims from three separate lawsuits...more

Health Care Compliance Association (HCCA)

CMS to Take Back Money It Returned Under Site-Neutral Payment Policy

Report on Medicare Compliance 30, no. 2 (January 18, 2021) - CMS is taking back money from hospitals for outpatient clinic visits provided in 2019 at excepted off-campus provider-based departments (PBDs) after returning...more

Baker Donelson

D.C. Appeals Court Upholds CMS's Authority to Limit Payment for E&M Services at Off-Site Provider-Based Locations

Baker Donelson on

The United States Court of Appeals for the District of Columbia recently upheld CMS's authority to expand site-neutral payment reductions for evaluation and management (E&M) services provided at longstanding off-campus...more

McGuireWoods LLP

D.C. Circuit Reversal Upholds CMS’ Site-Neutrality Cuts for Off-Campus Provider-Based Departments

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The U.S. Court of Appeals for the D.C. Circuit recently reversed a district court ruling and upheld the Centers for Medicare & Medicaid Services site-neutrality payment cuts for off-campus outpatient hospital clinic visits....more

Bricker Graydon LLP

CMS delays activation of systematic validation edits for OPPS providers with multiple service locations until further notice

Bricker Graydon LLP on

On March 24, 2020, the Centers for Medicare & Medicaid Services (CMS) announced a delay until further notice to the activation of systematic validation edits for OPPS providers with multiple locations. After multiple prior...more

Bricker Graydon LLP

Medicare Administrative Contractors request hospitals to verify practice locations

Bricker Graydon LLP on

A Medicare Administrative Contractor (MAC) recently sent letters to some Medicare participating hospitals asking them to verify their hospital practice locations based on the information the MAC has from the hospital’s...more

King & Spalding

Hospitals Ask Appeals Court to Affirm Their Victory in Off-Campus Provider-Based Department Rate Cut Saga

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On Thursday, February 20, 2020, hospitals represented by King & Spalding that operate excepted off-campus provided-based outpatient departments (PBDs) filed their brief in federal appeals court to preserve the victory they...more

King & Spalding

CMS to Repay Hospitals for 2019 Off-Campus Clinic Visit Services

King & Spalding on

CMS and its contractors have announced that beginning January 1, 2020, the agency will repay hospitals for underpaid evaluation and management (E/M) services provided in excepted off-campus provider-based departments during...more

Bricker Graydon LLP

Federal court denies American Hospital Association review of CMS 2020 site-neutral payment cuts for hospital off-campus...

Bricker Graydon LLP on

On December 16, 2019, the U.S. District Court for the District of Columbia ruled that its 2019 decision invalidating the Center for Medicare and Medicaid Services’ (CMS) site-neutral payment cuts does not automatically vacate...more

Katten Muchin Rosenman LLP

Health Care Law Perspectives - November 2019 • Volume I

CMS’ 340B Rate Cut Continues to Dampen Hospital Outpatient Expansion Efforts - Hospitals hoping to benefit from favorable 340B drug pricing when acquiring independent physician practices for conversion to hospital...more

King & Spalding

CMS Publishes Final Rule for CY 2020 Hospital Outpatient Prospective Payment System

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n November 1, 2019, CMS posted the final rule establishing the payment rates for the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgery Center (ASC) Payment System for calendar year (CY) 2020...more

Bricker Graydon LLP

CMS announces continuation of second year of site-neutral payment cuts

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Despite a court ruling against its site-neutral policy in September 2019, in the Calendar Year (CY) 2020 Medicare Outpatient Prospective Payment System (OPPS) final rule, released on November 1, 2019, the Centers for Medicare...more

Polsinelli

CMS Delays Price Transparency, Doubles Down on Site-Neutral and 340B Payment Policies in CY 2020 OPPS Final Rule

Polsinelli on

Late last week, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment System (“OPPS”) final rule [CMS-1717-FC]. While many hospitals had hoped for relief from recent...more

Baker Donelson

D.C. Court Rejects CMS's 2018 "Budget Neutrality" Policy

Baker Donelson on

In a September 17, 2019 decision, the United States District Court for the District of Columbia invalidated a CMS rule expanding site-neutral payment reductions to evaluation and management (E&M) services furnished in...more

Katten Muchin Rosenman LLP

Court Invalidates Latest CMS Effort to Reduce Reimbursement at Off-Campus Hospital Outpatient Departments

Key Points - ·On September 17, 2019, the District Court for the District of Columbia rejected the Centers for Medicare and Medicaid Services’ (CMS) latest attempt to limit Medicare reimbursement at off-campus outpatient...more

ArentFox Schiff

DC District Court Judge Rules Against CMS’s Site-Neutral Policy, Vacates CY 2019 Outpatient Prospective Payment System (OPPS)...

ArentFox Schiff on

On September 17, 2019, the US District Court for the District of Columbia ruled in American Hospital Association, et al. v. Alex Azar, II, et al that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory...more

McGuireWoods LLP

CMS’s Site-Neutrality Payment Cuts Lose in D.C. District Court

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On Sept. 17, 2019, a Washington, D.C. district court judge ruled that the Centers for Medicare & Medicaid Services (CMS) “exceeded its statutory authority when it cut the payment rate for clinic services at off-campus...more

King & Spalding

Victory for Hospitals as Judge Rules that CMS’s Reduction of Medicare Payments for Outpatient E&M Services Was Ultra Vires

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On September 17, 2019, U.S. District Judge Rosemary M. Collyer of the U.S. District Court for the District of Columbia awarded summary judgment in favor a group of more than 40 hospitals on their challenge to CMS’s decision...more

Brownstein Hyatt Farber Schreck

Court Vacates Rule That Lowered Medicare Payments to Off-Campus Clinics

Hospitals can breathe (at least temporarily) a sigh of relief as the U.S. District Court for the District of Columbia determined that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority when it...more

Foley & Lardner LLP

Site-Neutral Hospitals Find Reprieve for their Outpatient Departments Through the Courts

Foley & Lardner LLP on

On September 17, 2019, the D.C. District Court held that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority when it cut the payment rate for clinic services at off-campus provider-based...more

Sheppard Mullin Richter & Hampton LLP

D.C. District Court Vacates CMS Final Rule, Finds that CMS’ Lesser Reimbursement of Services Provided at Grandfathered Off-Campus...

On September 17, 2019, the U.S. District Court for the District of Columbia ruled against the Centers for Medicare and Medicaid Services (“CMS”), vacating CMS’ 2018 Final OPPS Rule, which cut Medicare reimbursement rates for...more

Bricker Graydon LLP

Federal court invalidates CMS site-neutral payment cuts for hospital off-campus provider-based locations

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On September 17, 2019, the United States District Court for the District of Columbia ruled that the Center for Medicare and Medicaid Services (CMS) exceeded its authority and failed to follow the statutory process for setting...more

K&L Gates LLP

K&L Gates Triage: Activation of Validation Edits for OPPS Providers with Multiple Service Locations

K&L Gates LLP on

The Centers for Medicare and Medicaid Services (CMS), recently announced that it plans to activate systematic validation edits for Outpatient Prospective Payment System (OPPS) providers with multiple service locations that...more

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