News & Analysis as of

Two-Midnight Rule Recovery Audit Contractors (RACs)

Poyner Spruill LLP

CMS Lifts Temporary Suspension of Short Stay Reviews

Poyner Spruill LLP on

Effective September 12, 2016, Beneficiary and Family Centered Care (BFCC) Quality Improvement Organizations (QIOs) resumed their hospital initial patient status reviews. The purpose of these reviews is to determine the...more

King & Spalding

CMS Finalizes Significant Changes to the Two Midnight Rule in the 2016 OPPS Final Rule

King & Spalding on

On October 30, 2015, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2016 Outpatient Prospective Payment System Final Rule (2016 OPPS Final Rule). In the 2016 OPPS Final Rule, CMS finalizes...more

King & Spalding

Annual RAC Report Shows Significant Drop in Recoveries by CMS in 2014

King & Spalding on

On October 15, 2015, CMS released its annual recovery auditing report to Congress. CMS’s Recovery Auditor (RAC) program identifies and corrects improper payments through a combination of prepayment and post-payment reviews,...more

King & Spalding

Also In The News - Health Headlines - August 2015 #4

King & Spalding on

President Obama Signs Outpatient Status Notification Bill On August 6, 2015, President Obama signed the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act. This legislation requires hospitals...more

Foley & Lardner LLP

Another Delay for the Two-Midnight Rule

Foley & Lardner LLP on

The Centers for Medicare and Medicaid Services (CMS) announced, on August 12, 2015, that it has extended the enforcement delay of the controversial two-midnight rule governing short hospital stays until the end of the year....more

K&L Gates LLP

Cinderella May Not Turn Into a Pumpkin After All: The Proposed Relaxation of the Two-Midnight Rule

K&L Gates LLP on

On July 8, 2015, the Centers for Medicare and Medicaid Services (“CMS”) released a Proposed Rule regarding the 2016 Hospital Outpatient Prospective Payment System (“OPPS”). The Proposed Rule, in addition to proposing updates...more

King & Spalding

CMS Releases CY 2016 Proposed Rule on OPPS and ASC Payment Systems, Including Changes to the Two Midnight Rule

King & Spalding on

On July 1, 2015, CMS released a Proposed Rule that would revise the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System payment rates for calendar year (CY) 2016, and would...more

McDermott Will & Emery

CMS Proposal Broadens Medicare Inpatient Reimbursement Eligibility Under the “2-Midnight Rule"

On July 1, 2015, the Centers for Medicare & Medicaid Services (CMS) released proposed updates to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for Calendar Year...more

K&L Gates LLP

MACRA Brings Modifications to the Recovery Audit Program

K&L Gates LLP on

This is the second K&L Gates Health Care Client Alert discussing the “Medicare Access and CHIP Reauthorization Act of 2015” (MACRA), signed into law by President Barack Obama on April 16, 2015. This alert focuses on...more

Faegre Drinker Biddle & Reath LLP

Critical Access Hospital Soothsayers and the 96-Hour Physician Certification Requirement

This year critical access hospitals (CAH) have struggled to implement procedures to comply with both the "two-midnight" rule and the 96-hour physician certification requirement. The combination of both puts physicians in a...more

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