News & Analysis as of

Outpatient Prospective Payment System (OPPS)

CMS Proposes Reimbursement Cuts for Certain Hospital Provider-Based Departments

by McGuireWoods LLP on

Non-excepted hospital off-campus provider-based departments (PBDs) may once again face cuts to reimbursement during calendar year 2018 (CY 2018) if the Centers for Medicare & Medicaid Services (CMS) finalizes proposed changes...more

CMS Outpatient Advisory Panel Speaks Out Against Planned 340B Cuts

by King & Spalding on

On August 21, 2017, a CMS advisory panel consisting of provider representatives recommended that CMS not finalize its proposed rule to reduce payments for outpatient drugs to hospitals under the 340B Drug Pricing Program....more

CMS Merely Soliciting Comments on Including Total Joints as ASC Procedures

by Tucker Arensberg, P.C. on

CMS released the proposed update for the Hospital Outpatient Perspective Payment System and the Ambulatory Surgery Center System on July 13, 2017, and the release has generated some unexpected controversy regarding the...more

K&L Gates Triage: 340B Regulatory Update: CMS Proposal and Draft Executive Order Could Have Big Impact on 340B Program

by K&L Gates LLP on

cmsThis episode outlines the basics of the 340B Drug Pricing Program and discusses potential changes affecting the program, including CMS’s recent proposal to cut reimbursement for Part B drugs purchased under the 340B...more

K&L Gates Triage: 340B Eligibility - Hospital Covered Entities

by K&L Gates LLP on

This podcast focuses on the eligibility requirements for hospitals participating in the 340B Drug Pricing Program. Factors affecting eligibility include a hospital’s licensure status, patient population, and Medicare...more

340B Covered Entities Beware: CMS Proposes Drastic Drug Reimbursement Rate Cuts

by Polsinelli on

In its Outpatient Prospective Payment System proposed rule ("Proposed Rule"), CMS outlined a significant Medicare Part B payment reduction for separately payable, nonpassthrough drugs provided in the hospital outpatient...more

CMS May Decide to Permit Labs to Bill for Certain Tests Provided to Outpatients

In the recently published proposed rule related to the CY 2018 Hospital Outpatient Prospective Payment System (OPPS), the Centers for Medicare & Medicaid Services (CMS) announced that it is considering changes to the...more

CMS Proposes to Reduce Facility Payment for Non-Excepted Provider-Based Outpatient Department Services by 50 Percent

by Baker Ober Health Law on

CMS recently proposed to reduce the facility fee for non-excepted off-campus provider-based hospital departments (OPBDs) from 50 percent of the Medicare Physician Fee Schedule (MPFS) amount to 25 percent of the MPFS amount....more

CMS Proposes Substantial Payment Reductions in CY 2018 for Off-Campus Hospital Outpatient Departments Subject to the Site-Neutral...

by K&L Gates LLP on

On July 20 and 21, 2017, respectively, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule addressing changes to the hospital Outpatient Prospective Payment System (“OPPS Proposed Rule”) and Medicare...more

CMS Releases Proposed 2018 Medicare Payment Regulations

by Baker Ober Health Law on

On July 13, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2018 Physician Fee Schedule that would update payment policies, payment rates and quality provisions for physicians and other medical...more

CMS Proposes Medicare Physician Fee Schedule Update for 2018

by Reed Smith on

The Centers for Medicare & Medicaid Services (CMS) has published its proposed rule to update the Medicare physician fee schedule (PFS) for calendar year (CY) 2018. The proposed rule addresses numerous Medicare policies,...more

CMS Proposes Medicare OPPS, ASC Update for CY 2018

by Reed Smith on

CMS has published its proposed rule to update Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) payment system rates and policies for calendar year (CY) 2018. In addition to...more

2018 Proposed Rules: Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System

by King & Spalding on

On July 13, 2017, CMS issued the Calendar Year (CY) 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System (ASCPS) proposed rule (Proposed Rule). CMS proposes to update OPPS...more

CMS’s 2018 Medicare Physician Fee Schedule Proposed Rule Would Slash Non-Excepted Provider-Based Department Payments

by Dorsey & Whitney LLP on

The Centers for Medicare & Medicaid Services (CMS) released its 2018 Medicare Physician Fee Schedule proposed rule on July 13, 2017. The proposed rule, among other things, proposes to cut Medicare payments for services...more

CMS Proposes Reimbursement Reduction for 340B Drugs

by Baker Ober Health Law on

When CMS issued its proposed rule for OPPS and ASC Payment System on July 13, the agency included a proposal to substantially scale back reimbursement for Part B drugs to hospitals participating in the federal 340B Drug...more

Significant Cuts Proposed to Medicare Payments for 340B Drugs

by McDermott Will & Emery on

As part of the CY 2018 proposed updates to the Medicare Hospital OPPS, the US Department of Health and Human Services has proposed to decrease Medicare Part B payments to hospitals for 340B drugs by almost 30 percent. The cut...more

Medicare Proposes Continued Relief for Critical Access and Rural Hospitals Through 2-Year Moratorium on Direct Supervision...

by Dorsey & Whitney LLP on

On July 13, 2017, CMS released a proposed rule as part of its 2018 Outpatient Prospective Payment System proposals that is aimed at helping to reduce some of the burdens rural hospitals experience in recruiting physicians....more

Six Questions and Answers About CMS’ Recommended Changes to 340B Medicare Reimbursement

In March, I posted about the Uncertain Future of the 340B Drug Discount Program.  When opining about What Could Happen Next I speculated about possible changes to government reimbursement for 340B drugs “so that government...more

340B Update: CMS Proposes to Reduce 340B Drug Reimbursement; Draft Executive Order Could Mean Further Changes to the 340B Program

by K&L Gates LLP on

The Trump administration is considering significant changes relating to the 340B Drug Pricing Program (“340B Program”), which allows certain categories of safety net providers to access discounted pricing on covered...more

The Opportunities and Challenges of Freestanding Emergency Departments

Following our blog post regarding the retail clinic movement, “Patient Check-Ups Before Checking Out: Partnering to Bring Health Care into the ‘One-Stop Shopping’ Sector” (April 19, 2017), we continue our examination of...more

2017 Brings Big Changes for Off-Campus Provider-Based Facilities

by Williams Mullen on

Historically, the Centers for Medicare and Medicaid Services (CMS) has reimbursed items and services furnished by provider-based departments (PBDs), both on and off campus, under the Medicare Hospital Outpatient Prospective...more

New Resources for Telehealth Chronic Care Management (CCM) Rules

by Foley & Lardner LLP on

More good news for hospitals, health care providers, and entrepreneurs interested in telehealth and Chronic Care Management (CCM). CMS just recently introduced a new educational initiative called Connected Care: the Chronic...more

Mid-Build Provider-Based Department (PBD) Attestation Filing Deadline Fast Approaching (Checklist Included)

by Williams Mullen on

Providers seeking to classify certain off-campus departments as “mid-build” for purposes of eligibility for Hospital Outpatient Prospective Payment System (OPPS) reimbursement must file a provider-based attestation with their...more

Feb. 13 Deadline Looms for Provider-Based Departments Seeking Mid-Build Exception

by Polsinelli on

A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (off-campus PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build...more

Reimbursement Changes for Hospital Off-Campus Provider-Based Departments

by McGuireWoods LLP on

Off-campus provider-based departments (PBDs) of hospitals face changes in reimbursement beginning Jan. 1, 2017, the effective date of the Centers for Medicare & Medicaid Services (CMS) outpatient prospective payment system...more

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