Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Why You Should Enter into a Payment Plan with a Junk Debt Buyer
The IRS recently issued two Q&As on the subject of employer payment plans, the purpose of which was to again underscore that arrangements purporting to allow an employer to reimburse employees on a pre-tax basis for premiums...more
Recently issued guidance clarifies the application of certain provisions under the Affordable Care Act (ACA) to health reimbursement arrangements, employer payment plans, health flexible spending arrangements and employee...more
Plan sponsors should review their health reimbursement arrangements, employer payment plans, health flexible spending arrangements, and employee assistance programs to ensure they comply with ACA market reforms....more
On September 23, 2013, CMS published a proposed rule to overhaul the payment methodology for federally qualified health centers (FQHCs). The proposed rule will change FQHC reimbursement from an all inclusive rate (AIR),...more
On September 6, 2013, CMS published in the Federal Register a correction to its previously published annual Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule for calendar...more
CMS, in its federal fiscal year (FFY) 2014 final rule, has allowed its five-year moratorium on the 25 percent threshold payment adjustment policy to expire. Following the lifting of this moratorium, LTCHs that admit more than...more
In the fiscal year 2014 Inpatient Prospective Payment System (IPPS) rule published in the Federal Register on August 19, 2013, CMS took two steps of note regarding the Medicare disproportionate share hospital (DSH)...more
CMS has released the FY 2011 SSI data for IPPS hospitals, LTCHs, and IRFs. This data will be used to determine the disproportionate share adjustment for hospitals and the low-income payment adjustment for IRFs for cost...more
On August 2, 2013, CMS released the annual Hospital Inpatient Prospective Payment System Final Rule for FY 2014 (the “Final Rule”), effective for discharges occurring on or after October 1, 2013....more
On June 11, 2013, the D.C. Circuit Court issued the latest ruling relating to the proper calculation of hospitals’ disproportionate share hospital (DSH) payment, leading to potentially lower Medicare reimbursements related to...more
On May 2, 2013, CMS released a proposed rule [PDF] for the Inpatient Rehabilitation Facility Prospective Payment System for fiscal year (FY) 2014. The proposed rule sets forth Medicare payment policies and rates governing...more
Former U.S. Supreme Court Justice Louis D. Brandeis once said that "Sunlight is the best disinfectant." The release of charges billed by some 3,337 Medicare hospitals for 100 of the most common inpatient diagnosis related...more
On May 8, 2013, the OIG issued an update that supersedes and replaces its 1999 Special Advisory Bulletin, The Effect of Exclusion from Participation in Federal Health Care Programs. The updated bulletin continues to stress...more
OIG continues its aggressive interpretation of scope and effect of exclusion from participation in Federal health care programs and clarifies several open questions....more
Effective October 1, 2013, CMS will begin paying disproportionate share hospitals differently. Congress ordered the change to the disproportionate share hospital (DSH) adjustment payment methodology as part of the Patient...more