Allison Cohen at Baker Donelson

Noteworthy GME Payment Policies and Opportunities for Residency Slots in CMS's FY 2025 IPPS Final Rule

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

8/26/2024 / Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , GME , Health Care Providers , Healthcare Facilities , Healthcare Workers , Hospitals , Inpatient Prospective Payment System (IPPS) , Mental Health , Rural Health Care Providers , Teaching Hospitals

How to Apply and Who's Eligible for Millions of Dollars in Funding Available for New Residency Programs and Expansions Through...

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

8/26/2024 / Ambulatory Surgery Centers , Federal Funding , Funding , Grants , Health Care Providers , Healthcare Facilities , Healthcare Workers , Hospitals , HRSA , Labor Shortage , Mental Health , Public Health Service (PHS) , Rural Areas , Rural Health Care Providers , Teaching Hospitals

CMS Proposes Significant Changes to the Medicare Shared Savings Program and 60-Day Rule

Under the CY 2025 Medicare Physician Fee Schedule (PFS) proposed rule, CMS proposes several modifications to the Medicare Shared Savings Program (MSSP) that would become effective in performance year 2025. CMS also proposed...more

8/9/2024 / Affordable Care Act , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medical Reimbursement , Medicare , Overpayment , Physician Fee Schedule , Physicians

CMS Proposes Extending COVID-Era Telehealth and Supervision Flexibilities through CY 2025

The Centers for Medicare & Medicaid Services (CMS) proposed to extend a number of COVID-era regulatory flexibilities related to telehealth, remote services, and supervision in the CY 2025 Medicare Physician Fee Schedule (PFS)...more

7/30/2024 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Health Care Providers , Healthcare , Medicare , Mental Health , Physician Fee Schedule , Physicians , Proposed Rules , Substance Abuse , Telehealth , Telemedicine

Noteworthy GME Payment Policy Takeaways from the CMS FY 2025 IPPS Proposed Rule

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

5/22/2024 / Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , GME , Healthcare Facilities , Hospitals , Inpatient Prospective Payment System (IPPS) , Medicare , Physicians , Proposed Rules , Rural Health Care Providers , Teaching Hospitals

2024 Medicare Physician Fee Schedule Final Rule Extends COVID-19 Telehealth Policies and Includes Bonus Extension

The CY 2024 Medicare Physician Fee Schedule Final Rule (Final Rule) implemented several statutory extensions to COVID-19 telehealth waivers and flexibilities, finalized proposed policies, and extended an important telehealth...more

11/15/2023 / Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , Health Care Providers , Hospitals , Medicare , Physician Fee Schedule , Physicians , Reimbursements , Telehealth

DEA and HHS Extend Telemedicine Flexibilities for Controlled Substance Prescriptions Through 2024

On October 6, 2023, the Drug Enforcement Agency (DEA) and the Department of Health and Human Services (HHS) announced they would further extend the COVID-19 flexibilities allowing for telemedicine prescription of controlled...more

10/16/2023 / Controlled Substances , DEA , Department of Health and Human Services (HHS) , Health Care Providers , Prescription Drugs , Telehealth , Telemedicine

Significant 2024 Medicare Physician Fee Schedule Rule Proposals: E/M, Social Determinants of Health, and Behavioral Health

In this article, we highlight a number of policy proposals in the current year (CY) 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule that have significant health care delivery and operational implications. These...more

8/14/2023 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Proposed Rules , Risk Assessment , Telehealth

CY 2024 Medicare Physician Fee Schedule: Extending Telehealth Flexibilities and Seeking Future Policy Input

CMS recently released the CY 2024 Medicare Physician Fee Schedule (MPFS) Proposed Rule (Proposed Rule), which included many noteworthy proposals and clarifications related to Medicare telehealth services and other remote...more

7/24/2023 / Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Telehealth , Telemedicine

Baker's Dozen: What Are Your Best "Balance" Tips?

We recently asked our Firm's "Women to Equity" class members about their best tips on achieving "balance." These women, are all on a path towards equity, balancing busy work schedules and client relationships with their...more

6/28/2023 / Law Firm Associates , Professional Development , Women in the Law , Young Lawyers

Making Sense of the Varying End Dates of Telehealth Waivers and Flexibilities When the PHE Ends on May 11th

With the COVID-19 Public Health Emergency (PHE) ending on May 11th, providers and practitioners must carefully consider the dates when various telehealth waivers and flexibilities end. This requires understanding the...more

5/10/2023 / Health Care Providers , Home Health Care , Hospitals , Medicare , Physician Fee Schedule , Public Health Emergency , SAMHSA , Telehealth , Waivers

While the Public Health Emergency (PHE) is Projected to End May 11, Medicare Telehealth Coverage Expansions Were Extended Through...

President Biden recently announced that his administration plans to end the COVID-19 PHE on May 11, 2023. This provides more clarity about the long-anticipated end date for certain telehealth waivers and enforcement...more

2/14/2023 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Department of Health and Human Services (HHS) , Health Care Providers , Medicare , Public Health Emergency , Telehealth , Telemedicine

Public Health Emergency Declaration Again Extended; Key Flexibilities Decoupled

On January 11, 2023, Department of Health and Human Services (HHS) Secretary Xavier Becerra again renewed the declaration of a Public Health Emergency (PHE) under the Public Health Service Act, extending the declaration...more

1/19/2023 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Health Care Providers , Medicaid , Public Health Emergency , Telehealth

Noteworthy Telehealth and Remote Services Provisions in the CY 2023 Medicare PFS Final Rule

On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) Final Rule. This article highlights noteworthy provisions of the Final Rule...more

11/21/2022 / Centers for Medicare & Medicaid Services (CMS) , Final Rules , Health Care Providers , Medicare , Physician Fee Schedule , Telehealth , Telemedicine

Safeguarding Against Discrimination in Telehealth to Meet Requirements of New Federal Guidance and the Proposed Rule Implementing...

With telehealth becoming increasingly prevalent, the federal government has taken steps to protect against discrimination in telehealth and prevent accessibility issues that disproportionately affect individuals with...more

8/31/2022 / Affordable Care Act , Department of Health and Human Services (HHS) , Disability Discrimination , Health Care Providers , Reasonable Accommodation , Section 1557 , Telehealth , Telemedicine

Key Telehealth Proposals in Calendar Year 2023 Medicare Physician Fee Schedule Proposed Rule

On July 29, 2022, the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) proposed rule was published in the Federal Register. The proposed rule includes several noteworthy proposals related to telehealth and other...more

8/5/2022 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Physician Fee Schedule , Telehealth , Telemedicine

Telehealth Flexibilities Get Another Shot through a Temporary Extension under the Omnibus Spending Bill

On March 15, 2022, President Biden signed the Consolidated Appropriations Act, 2022, an omnibus bill which includes, among other spending measures, a five-month extension of regulatory flexibilities that have allowed for...more

3/29/2022 / CARES Act , Centers for Medicare & Medicaid Services (CMS) , Consolidated Appropriations Act (CAA) , Coronavirus/COVID-19 , Health Care Providers , Telehealth , Time Extensions

Convening and Co-Provider Responsibilities under the No Surprises Act

The No Surprises Act (NSA), which took effect on January 1, 2022, includes protections from surprise bills for patients who are uninsured or covered under group or individual plans. It will be necessary for both facilities...more

2/28/2022 / Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Health Care Providers , Health Insurance , Medical Expenses , Medical Reimbursement , New Legislation , Surprise Medical Bills

CMS Releases Final Rule Implementing New GME Policies and Finalizing the Methodology to Distribute 1,000 Medicare GME Slots

The long-awaited FY 2022 Inpatient Prospective Payment System (IPPS) Final Rule with Comment Period (Final Rule) addressing changes to Medicare Graduate Medical Education (GME) Payments for Teaching Hospitals was placed on...more

12/24/2021 / Centers for Medicare & Medicaid Services (CMS) , Graduate Medical Education , Healthcare Reform , Inpatient Prospective Payment System (IPPS) , Medical Reimbursement , Medicare

CY 2022 Changes to Split (or Shared) Visit, Critical Care and Teaching Physician Billing

In preparation for the beginning of calendar year 2022, we want to highlight several important policies in the CY 2022 Medicare Physician Fee Schedule (PFS) final rule (Final Rule) related to billing for teaching physician...more

12/24/2021 / Final Rules , Health Care Providers , Healthcare , Healthcare Reform , Medical Reimbursement , Medicare , Physician Fee Schedule

Key Telehealth Provisions in the Calendar Year 2022 Physician Fee Schedule Final Rule

On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) final rule (Final Rule), which finalized several noteworthy policies related...more

11/11/2021 / Centers for Medicare & Medicaid Services (CMS) , Final Rules , Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Telehealth

OIG Reports Highlight State Challenges and Call for Increased Oversight to Improve the Provision of Medicaid Behavioral Health...

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently issued two data briefs addressing challenges with the provision of behavioral health services to Medicaid enrollees, and calling for...more

10/5/2021 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Medicaid , OIG , Regulatory Oversight , Telehealth

Telehealth, Split or (Shared) Visit, Critical Care, and Teaching Physician Billing Proposals in the CY 2022 Medicare Physician Fee...

On July 13, 2021, CMS released the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) proposed rule, which includes several noteworthy proposals related to telehealth, billing for split (or shared) visits, critical...more

7/29/2021 / Health Care Providers , Medicare , Physician Fee Schedule , Physicians , Reimbursements , Telehealth , Telemedicine

CMS Extends GME Affiliation Agreement Deadline

Under section 1135(b)(5) waiver authority, CMS once again extended the submission deadline for both new Medicare graduate medical education (GME) affiliation agreements and amendments to existing Medicare GME affiliation...more

6/16/2021 / Centers for Medicare & Medicaid Services (CMS) , Deadlines , GME , Health Care Providers , Medicare

Fiscal Year 2022 IPPS Proposals Related to GME Payments

The FY 2022 Inpatient Prospective Payment System (IPPS) Proposed Rule implements the three noteworthy Graduate Medical Education (GME) provisions included in the Consolidated Appropriations Act, 2021 (CAA). As explained in...more

5/18/2021 / Centers for Medicare & Medicaid Services (CMS) , Graduate Medical Education , Health Care Providers , Hospitals , Medicare , Reimbursements , Rural Health Care Providers

Allison Cohen

Baker Donelson

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