Adam Romney on Centers for Medicare & Medicaid Services (CMS)

Time, Gravity, and the Complexity of Stark: 2022 MPFS Stark Proposals

There are three things that cannot be stopped: time, gravity, and the increasing complexity of the Stark Law. To be fair, complexity has not been the goal of the Centers for Medicare & Medicaid Services (CMS). Rather, Stark's...more

7/22/2021 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , MPFS , Physicians , Stark Law

Done Sprinting, but Are We There Yet? The Value-Based Stark Exceptions and AKS Safe Harbors

On December 2, 2020, CMS and OIG finished a two-year sprint to modernize the Stark and Anti-Kickback (AKS) regulations to remove barriers to value-based care and incentivize patient-centered care coordination....more

12/4/2020 / Anti-Kickback Statute , Centers for Medicare & Medicaid Services (CMS) , Exceptions , Hospitals , OIG , Physicians , Safe Harbors , Stark Law , Value-Based Care

CMS Finalizes Hospital Pricing Transparency Rule

On November 15, 2019, CMS published a controversial final rule intended to improve hospital pricing transparency for consumers....more

12/2/2019 / Centers for Medicare & Medicaid Services (CMS) , Final Rules , Health Care Providers , Hospitals , Pricing Requirements , Transparency

Sprint Regulations: Value-Based Stark Exception and AKS Safe Harbors

The Value-Based Proposals: Turning Tides or Shifting Sands? Industry stakeholders have waited with bated breath to see whether CMS and OIG would offer meaningful changes to the Stark and AKS landscape in support of the...more

10/30/2019 / Anti-Kickback Statute , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , OIG , Safe Harbors , Stark Law

“Bundles of Bundles”: CMS Announces New Mandatory Bundled Payment Programs for Heart Attack, Heart Surgery, and Hip and Femur...

The Centers for Medicare and Medicaid Services (“CMS”) is forging ahead with the implementation of innovative and value-based payment programs, despite Donald Trump’s win in the presidential election and Republican...more

1/9/2017 / Alternative Payment Models (APM) , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Health Care Providers , Medicare , Medicare Access and CHIP Reauthorization (MACRA)

Tick, Tock, Shock: CMS Provides Welcome Guidance in the Final Regulation for 60-Day Rule

On Feb. 12, 2016, CMS published the much anticipated final regulations implementing the so-called “60-Day Rule.” Congress adopted the 60-Day Rule as part of the Affordable Care Act (ACA). The Rule requires health care...more

2/16/2016 / 60-Day Rule , Centers for Medicare & Medicaid Services (CMS) , False Claims Act (FCA) , Health Care Providers , Medicaid , Medicare , Overpayment Recovery Time Limits

Medicare to Implement CJR: Mandatory Bundled Payment Program for Joint Replacement Surgeries

On Nov. 24, the Centers for Medicare & Medicaid Services will publish in the Federal Register the final rule for the Comprehensive Care Joint Replacement (CJR) Program. The CJR Program is a new payment model that requires...more

11/24/2015 / Centers for Medicare & Medicaid Services (CMS) , Fee-for-Service , Healthcare , Healthcare Fraud , Payment Methods , Telehealth

Changes to the “Two-Midnight Rule” on the Horizon

On July 1, CMS published proposed changes to the so-called “Two-Midnight Rule,” which currently governs when inpatient hospital admissions are entitled to Medicare Part A payment. The proposed changes were announced in a...more

7/7/2015 / Centers for Medicare & Medicaid Services (CMS) , Healthcare , Hospitals , Inpatient Billing , Medicare , Patient Prospective Payment System , Proposed Amendments , Two-Midnight Rule

Finishing at the Top of the Class: The Risks Faced by High Achievers on the Medicare Billings List

In this increasingly competitive world, providers generally want to be at the top of almost any official ranking. CMS’s recently released list of medical groups and physicians receiving the most Medicare reimbursement dollars...more

6/26/2014 / Centers for Medicare & Medicaid Services (CMS) , Healthcare , Medicare

Emerging EHR Risks: When Documentation May Not Be Enough (or Too Much)

Today’s Electronic Health Record (EHR) technologies feature many tools that help providers practice more efficiently and allow them to spend more time caring for patients. However, the federal government recently has posted...more

4/17/2014 / Audits , Centers for Medicare & Medicaid Services (CMS) , EHR , Electronic Records , MACs , Medicare , OIG , Required Documentation , Risk Mitigation

Adam Romney

Davis Wright Tremaine LLP

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