Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector....more
On July 25, 2018, the Centers for Medicare & Medicaid Services (CMS) released the proposed Calendar Year (CY) 2019 Hospital Outpatient Prospective Payment (OPPS) Rule proposing, among other changes, to further restrict...more
The 21st Century Cures Act (the “Cures Act”) (Pub. L. No. 114-255), which was signed into law by President Obama on December 13, 2016, includes a number of important health care provisions, and several address the...more
In an August 26, 2016, letter to the Centers for Medicare & Medicaid Services (CMS), the American Hospital Association (AHA) expressed serious concern over the portion of the calendar year 2017 hospital outpatient prospective...more
Published on July 14, 2016, CMS’s proposed 2017 Hospital Outpatient Prospective Payment System (OPPS) rule calls for site-neutral payments that would stop Medicare payments to many off-campus facilities at the same level as...more
CMS Provides Update Regarding Patient Status Review Delay – On July 27, 2016 CMS posted an update regarding Quality Improvement Organization (QIO) reviews of patient status claims, which are currently paused. CMS notes that...more
In Depth - Background - On July 6, 2016, the Centers for Medicare & Medicaid Services (CMS) released the CY 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule, which includes proposed regulations to...more
On May 24, 2016, the U.S. House Ways and Means Committee approved legislation that would continue Hospital Outpatient Prospective Payment System (OPPS) payment for off-campus provider-based departments that were “mid-build”...more
On Wednesday May 18, 2016, members of the U.S. House Ways and Means Committee introduced a proposal to continue OPPS payment for those off-campus provider-based departments that were “mid-build” as of November 1, 2015. Under...more
The recently enacted Bipartisan Budget Act (P. L. 114-74) included a provision that will significantly alter the future of hospital-based outpatient care. The provision, Section 603, will exclude from Medicare’s...more
On November 2, President Obama signed into the law the Bipartisan Budget Act of 2015 (the “Act”), which contains language that will significantly change how hospital-based outpatient care is reimbursed....more
On November 2, 2015, President Obama signed into law H.R. 1314, the Bipartisan Budget Act of 2015 (the "Act"), which significantly changes Medicare reimbursement for off-campus hospital services. The Act, which Congress...more
On October 28 and 30, 2015, the U.S. House of Representatives and U.S. Senate approved the Bipartisan Budget Act of 2015 (the Act)—a measure designed to raise the limit on Federal borrowing that would also have significant...more
Without fanfare or any significant discussion, the Bipartisan Budget Act (Act) contains the first legislative action related to provider-based status—and it is a sweeping action with negative financial consequences to many...more
On October 28, 2015, the U.S. House of Representatives approved legislation that, if enacted, would, among other things, substantially alter how and how much Medicare pays for outpatient services furnished by hospitals. The...more
Legislation being drafted as part of a budget deal between members of Congress and the White House includes language that will significantly alter the future of hospital-based outpatient care. The “discussion draft” of the...more
On October 26, 2015, Congressional and White House budget negotiators released the legislative text of the Bipartisan Budget Act of 2015. The Act is aimed primarily at lifting the Federal debt limit and avoiding a looming...more
CMS just introduced proposed rules to clarify the requirements and payment opportunities when hospitals want to bill Medicare for Chronic Care Management (“CCM”) services. CCM is an exciting service covered by Medicare...more
In This Issue: - Medicare Releases Set of Payment Rules, Physician Fee Schedule on Deck - Implementation of the Affordable Care Act - Federal Regulatory Initiatives - Congressional Initiatives - Other...more