CMS's FY 2025 Inpatient Prospective Payment System (IPPS) Final Rule (Final Rule) finalizes several noteworthy proposals related to graduate medical education (GME) payment opportunities. Below are the takeaways from the...more
The Health Resources and Services Administration (HRSA) has issued two Teaching Health Center Graduate Medical Education (THCGME) notices of funding opportunities for the academic year (AY) 2024-2025 and AY 2025-2026. These...more
CMS's FY 2025 Inpatient Prospective Payment System (IPPS) Proposed Rule (Proposed Rule) includes several noteworthy proposals and requests for information related to graduate medical education (GME) payment policies. Below...more
"Informed consent" has been described as "a bedrock principle of healthcare in a free society," and if a "patient is denied the ability to exercise or even consider informed consent, the patient's personal liberty suffers."1...more
New guidance released by the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) on April 1, 2024, clarified that hospitals will not be eligible for Medicare or Medicaid...more
On April 1, 2024, the U.S. Department of Health and Human Services (“HHS”), through the Centers for Medicare & Medicaid Services (“CMS”), Center for Clinical Standards and Quality/Quality, Safety & Oversight Group, issued new...more
Centers for Medicare & Medicaid Service (CMS) revised hospital interpretive guidance in the State Operations Manual, Appendix A-Hospitals on April 1, 2024 in response to media stories of nation’s teaching hospitals and...more
Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more
Structure of AMCs - While every AMC is unique, there are some common characteristics that many share: (1) the hospital and school are often tethered together from an organizational, governance and/or legal perspective;...more
In a recent win for teaching hospitals, the U.S. District Court for the District of Columbia invalidated a CMS regulation implementing the direct graduate medical education (DGME) cap on full-time equivalent (FTE) residents....more
The Consolidated Appropriations Act, 2021, creates 1,000 new Medicare-funded graduate medical education (GME) residency positions, expands opportunities for rural residency training, and allows hospitals that have very low...more
Shortly before midnight on 21 December 2020, Congress passed with broad bipartisan support the Consolidated Appropriations Act, 2021, which contains $2.3 trillion in spending aimed at stimulating the economy and providing...more
As the calendar year draws to a close, hospitals with a 9/30 fiscal year end are working intensely on completing their FY 2019 Medicare cost reports. This seemed like a good time to remind everyone of some of CMS’s more...more
On June 17, 2019, the U.S. District Court of the District of Massachusetts rejected Massachusetts General Hospital’s (MGH) request to dismiss a qui tam complaint alleging that the teaching hospital fraudulently overbilled...more
Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq. (Title IX) has received a lot of attention recently for its impact on college athletic programs. Both male and female sports have grown increasingly...more
Recent Decision Highlights Potential Personal Liability of Hospital Directors Based on Breach of Fiduciary Duty - In a recent case, a federal bankruptcy court in Michigan reviewed important questions involving breach of...more
Hospital administrators are well aware their institutions are subject to a whole host of workplace-related federal statutes: Title VII of the Civil Rights Act, the Health Insurance Portability and Accountability Act (HIPAA),...more
On July 22, 2015, the U.S. House Ways & Means Health Subcommittee heard testimony from Mark Miller, Ph.D., executive director of Medicare Payment Advisory Commission (MedPAC). Dr. Miller’s testimony highlighted recent trends...more
CMS recently released data collected through the Open Payments Program in accordance with the Affordable Care Act from applicable manufacturers and group purchasing organizations (GPOs) about payments and other transfers that...more
On June 29, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published detailed information regarding payments made by pharmaceutical and medical device manufacturers to physicians and teaching hospitals during 2014...more
Although Medicare graduate medical education reimbursement can be a helpful source of financing to facilitate resident training, many community hospitals have suffered a “gotcha” moment when trying to establish new programs....more
The Open Payments database (the “Database”) is now live, and the first round of data is available to the public on the Centers for Medicare and Medicaid Services (“CMS”) website. This first round of data reflects “nearly 4.4...more
The guidance calls for 2014 reporting by April 1, 2015. When signed into law in March 2010, the Affordable Care Act (ACA) put a renewed focus on transparency. While section 6002, the Physician Payment Sunshine Act,...more
Teaching hospitals and physicians who speak at continuing medical education (CME) programs should be interested in a July 11, 2014, announcement by the Centers for Medicare & Medicaid Services (CMS). The announcement proposes...more
Academic Medical Centers and teaching hospitals (AMC/TH) are increasingly choosing to affiliate in some manner with other health care providers in order to surmount significant industry challenges. The first quarter of 2014...more