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D.C. Circuit Reversal Upholds CMS’ Site-Neutrality Cuts for Off-Campus Provider-Based Departments

The U.S. Court of Appeals for the D.C. Circuit recently reversed a district court ruling and upheld the Centers for Medicare & Medicaid Services site-neutrality payment cuts for off-campus outpatient hospital clinic visits....more

CMS Relaxes Guidance to Postpone Non-Essential Procedures: Six Key Points

The Centers for Medicare & Medicaid Services (CMS) recently released its first phase of recommendations regarding reopening medical facilities for the provision of non-emergent procedures unrelated to the 2019 novel...more

CMS Recommends Postponing Non-Essential Procedures During Pandemic – Seven Key Points

During this unprecedented public health emergency created by the novel coronavirus (COVID-19), in an effort to slow the spread, protect healthcare providers and consumers from exposure, and ensure healthcare resources remain...more

Seven Key Points From CMS’ Memo to Home Health Agencies About COVID-19

As part of the White House Coronavirus Task Force’s ongoing efforts to respond to and contain the spread of the 2019 novel coronavirus (COVID-19), on March 10, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a...more

HHS to Ease Fraud and Abuse Rules Part 1: Proposed Revisions to Existing Anti-Kickback Statute Safe Harbors

As discussed in a previous McGuireWoods alert, on Oct. 9, 2019, the Department of Health and Human Services announced two proposed rules to significantly amend the Physician Self-Referral Law (Stark Law), the federal...more

CMS’s Site-Neutrality Payment Cuts Lose in D.C. District Court

On Sept. 17, 2019, a Washington, D.C. district court judge ruled that the Centers for Medicare & Medicaid Services (CMS) “exceeded its statutory authority when it cut the payment rate for clinic services at off-campus...more

CMS Proposes Welcome Changes to Stark Law Advisory Opinion Process

The Centers for Medicare & Medicaid Services (CMS) recently issued its annual Physician Fee Schedule and Quality Payment Program Proposed Rule for calendar year 2020. Among other things, it addresses potential changes to...more

CMS Proposes Finalizing Payment Cuts for Off-Campus Hospital Clinic Visits

Last year, the Centers for Medicare & Medicaid Services (CMS) implemented a controversial payment cut to certain off-campus provider-based departments (PBDs) for the most commonly billed Outpatient Prospective Payment System...more

CMS Postpones OPPS “Exact Match” Address Requirements Until October 2019

The Centers for Medicare & Medicaid Services (CMS) recently announced it will postpone implementation of the “exact match” validation edits to the hospital outpatient prospective payment system (OPPS) until October 2019. Once...more

Claim Denials Ahead for Some Hospital Outpatient Providers

The Centers for Medicare & Medicaid Services (CMS) recently announced that it would soon deny claims based on a series of validation edits to Medicare enrollment systems. These validation edits will apply to hospital...more

CMS Implements Survey Process of Home Dialysis Services in Nursing Homes

Effective as of September 16, 2018, the Centers for Medicare and Medicaid Services (“CMS”) implemented a survey process for the provision of home dialysis services in long-term-care facilities (“LTC Facilities” or “Nursing...more

CMS Proposes More Payment Cuts for Hospital Off-Campus Provider-Based Departments

Since the passage of the Bipartisan Budget Act of 2015, certain off-campus provider-based departments (PBDs) have seen their payment rates cut by nearly 60 percent. Now, in its recently released calendar year (CY) 2019...more

New Medicare Cards to Debut in April 2018

In an effort to “prevent fraud, fight identity theft, and keep taxpayer dollars safe,” the Centers for Medicare and Medicaid Services (CMS) is issuing new Medicare cards to Medicare enrollees beginning in April 2018. This...more

2018 Reimbursement Cuts for Some Off-Campus Hospital Provider-Based Departments

On Nov. 2, 2017, the Centers for Medicare and Medicaid Services (CMS) finalized a rule changing reimbursement rates under the Medicare Physician Fee Schedule (MPFS) for certain non-excepted hospital off-campus provider-based...more

CMS Proposes Reimbursement Cuts for Certain Hospital Provider-Based Departments

Non-excepted hospital off-campus provider-based departments (PBDs) may once again face cuts to reimbursement during calendar year 2018 (CY 2018) if the Centers for Medicare & Medicaid Services (CMS) finalizes proposed changes...more

Reimbursement Changes for Hospital Off-Campus Provider-Based Departments

Off-campus provider-based departments (PBDs) of hospitals face changes in reimbursement beginning Jan. 1, 2017, the effective date of the Centers for Medicare & Medicaid Services (CMS) outpatient prospective payment system...more

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