On January 9, 2018, The Centers for Medicare & Medicaid Services (CMS) announced a new voluntary bundled payment model program – Bundled Payment for Care Improvement Advanced (BPCI Advanced). The episode payment model, which...more
On August 15, 2017, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (Proposed Rule) that, if finalized, would (1) reduce the number of Metropolitan Statistical Areas (MSAs) in which there is...more
Two recent announcements reflect that the U.S. Government is taking aggressive steps to address opioid abuse by identifying and targeting the involvement of medical professionals in facilitating opioid abuse involving Federal...more
7/21/2017
/ Attorney General ,
Department of Justice (DOJ) ,
Drug & Alcohol Abuse ,
Health Care Providers ,
Medicare Fraud Strike Force ,
Medicare Part D ,
OIG ,
Opioid ,
Pharmacies ,
Physicians ,
Prescribing Authority
Health Plans and health care providers are getting into each other’s business. This payor/provider convergence has taken different forms. Health systems have ventured into the health insurance business by acquiring or...more
“A robust, sustainable blood system is a crucial component of every health care system.” That is how Rand Corporation’s recently issued comprehensive report entitled “Toward a Sustainable Blood Supply in the United States”...more
On December 20, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (the Final Rule) which includes three new mandatory episode-based payment programs for cardiac care, as well as the expansion of the...more
In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”)....more
7/15/2016
/ 501(c)(3) ,
ACOs ,
Affordable Care Act ,
Exempt Organizations ,
Health Care Providers ,
Hospitals ,
IRS ,
Medicare Shared Savings Program ,
Physicians ,
Private Letter Rulings ,
Third-Party ,
Unrelated Business Income Tax
The Department of Justice’s antitrust division (the “DOJ”)and the State of North Carolina (“NC”) jointly sued, on June 9, 2016, Carolinas HealthCare System (“CHS”), the largest healthcare system in North Carolina, over...more
Continuing in its efforts to promote alternative payment models, on April 11, 2016, CMS announced the Comprehensive Primary Care Plus (CPC+) model. CMS hopes to implement CPC+ in up to 20 regions, accommodating up to 5,000...more
Approximately 800 hospitals in 67 Metropolitan Statistical Areas will begin mandatory participation in the Comprehensive Care for Joint Replacement (CJR) Model on April 1, 2016. The CJR bundled payment program applies to...more
The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule modifying the Medicare Shared Savings Program (MSSP) regulations (the “Rule”). Among other changes, the Rule proposes (a) to modify the...more
Accountable Care Organizations (ACOs) can share costs of telehealth and remote patient monitoring services among their hospitals, providers/suppliers, and other ACO participants, according to federal regulations under the...more
11/3/2015
/ ACOs ,
Alternative Payment Models (APM) ,
Centers for Medicare & Medicaid Services (CMS) ,
Fee-for-Service ,
Fraud and Abuse ,
Health Care Providers ,
Health Information Technologies ,
Healthcare ,
Healthcare Reform ,
Hospitals ,
Medicare ,
Medicare Shared Savings Program ,
OIG ,
Suppliers ,
Telehealth ,
Telemedicine ,
Value-Based Purchasing ,
Waivers
The Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) of the Department of Health and Human Services just issued a final rule setting forth waivers of specified fraud and abuse laws...more
11/2/2015
/ ACOs ,
Centers for Medicare & Medicaid Services (CMS) ,
Final Rules ,
Fraud and Abuse ,
Gainsharing ,
Healthcare ,
Home Health Care ,
Medicare ,
Medicare Shared Savings Program ,
OIG ,
Required Documentation ,
Waivers
The Centers for Medicare and Medicaid Services (CMS) released, on August 25, 2015, the quality and financial performance results for Medicare Accountable Care Organizations for 2014. CMS touted that Medicare ACOs continued to...more
9/10/2015
/ ACOs ,
Alternative Payment Models (APM) ,
Bundled Payments ,
Centers for Medicare & Medicaid Services (CMS) ,
Electronic Medical Records ,
Health Care Providers ,
Healthcare Costs ,
Medicare ,
Medicare Shared Savings Program ,
Physician Medicare Reimbursements ,
Quality of Care Standards
CMS, through the Center for Medicare and Medicaid Innovation, announced on September 1, 2015, the introduction of the Medicare Advantage Value-Based Insurance Design (VBID) Model as part of the Health Plan Innovations...more
9/4/2015
/ Beneficiaries ,
Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Cost-Sharing ,
Health Insurance ,
HMOs ,
Innovation ,
Medicare ,
Medicare Advantage ,
PPOs ,
Quality of Care Standards ,
Supplemental Benefits ,
Value-Based Purchasing
This is the fifth post in Health Care Law Today’s series on the final rule.
The final Medicare Shared Savings Program (“MSSP”) rule released on June 4, 2015, contains a number of modifications to the financial...more
This is the third post in Health Care Law Today’s series on the final rule. This post addresses changes to sharing of beneficiary identifiable data.
In its December 8, 2014 proposed rule revising the Medicare Shared...more
This is the second post in Health Care Law Today’s series on the final rule. This post addresses Eligibility Requirements, and the Application and the Renewal Process.
ACO Eligibility Requirements -
Under the...more
6/24/2015
/ ACO Participant Agreements ,
ACOs ,
Applications ,
Board of Directors ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Corporate Governance ,
Duty of Loyalty ,
Eligibility ,
Fiduciary Duty ,
Final Rules ,
Governance Standards ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Medicare Shared Savings Program ,
Renewal Options ,
Suppliers ,
Transparency
This is the first post in Health Care Law Today’s Series on the final rule.
The Centers for Medicare and Medicaid Services (“CMS”) released a final rule, on June 4, 2015, addressing changes to its Medicare Shared Savings...more
CMS announced a new ACO payment initiative on March 10, 2015, the Next Generation ACO Model, designed for entities experienced in coordinating care for populations of patients. The announcement reflects CMS’ commitment to...more
In This Issue:
- Executive Summary
- Improving Care by Tapping Into the Data Goldmine
- Big Opportunities Available in Big Data
- Government Programs Supporting the Use of Big Data
-...more
Cooperative Hospital Service Organizations (CHSOs) are organizations that are available for hospitals considering certain types of joint ventures with other hospitals. If the terms for their use strictly meet the regulatory...more
The Iowa Commissioner of Insurance (the “Commissioner”) filed a petition, on January 29, 2015, seeking to liquidate CoOpportunity Health, Inc. (“CoOpportunity”), a Consumer Operated and Oriented Plan (“CO-OP”) established...more
The Iowa Insurance Commissioner obtained an Order for Rehabilitation with respect to CoOportunity Health, Inc. (“CoOportunity”) on December 24, 2014. With the Rehabilitation Order, the Iowa Insurance Commission took...more
Many critics have suggested that the November 11, 2011 final rule establishing the MSSP created a financial model that over time would not be sustainable. ACOs viewed the requirement to take risk after the initial three years...more