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CMS Issues Transmittal Waiving Cap on Prior Year Payments for Nursing and Allied Health Education for Medicare Advantage Enrollees

On March 16, 2023, CMS issued Transmittal 11904, directing its contractors to adjust hospitals’ nursing and allied health education (NAH) payments associated with services furnished to Medicare Advantage (MA) enrollees. ...more

New Kidney Transplant Allocation Policy Survives Eighth Circuit Legal Challenge

On November 8, 2021, the Eighth Circuit affirmed a district court order that denied an attempt to preliminarily block the Organ Procurement and Transplant Network’s (OPTN) policy changing the manner in which donor kidneys are...more

OIG Issues Advisory Opinion on Arrangement for Charitable Organization to Buy and Forgive Patient Debt from Providers

On July 24, 2020, OIG issued an Advisory Opinion (AO), AO 20-04, regarding whether an arrangement where a charitable organization purchases or receives donations of unpaid medical debt from health care providers, and then...more

Hospitals Ask Appeals Court to Affirm Their Victory in Off-Campus Provider-Based Department Rate Cut Saga

On Thursday, February 20, 2020, hospitals represented by King & Spalding that operate excepted off-campus provided-based outpatient departments (PBDs) filed their brief in federal appeals court to preserve the victory they...more

President Trump Issues Executive Order Limiting Agency Use of Informal Guidance Documents

On October 9, 2019, President Trump issued an Executive Order aimed to curb agencies, such as CMS, from using informal guidance documents as de facto rules that have the binding effect of law. In a press conference...more

CMS Issues Final Rule Aimed to Reduce Burden on Providers and Suppliers Through Regulatory Reforms

On September 26, 2019, CMS issued a Final Rule that CMS intends will reform certain Medicare regulations related to standards and certifications that CMS identified as “unnecessary, obsolete, or excessively burdensome.” CMS...more

President Trump Issues Executive Order Aimed at Kidney Health in America

On July 10, 2019, President Trump issued an Executive Order on Advancing American Kidney Health aimed at reducing the number of patients developing kidney failure, having fewer Americans receiving dialysis in dialysis...more

President Trump Urges Congress to End “Surprise Medical Billing,” Bipartisan Legislation Expected but Ramifications for...

During a May 9, 2019 press event, President Trump urged Congress to pass legislation that would protect patients from surprise medical bills. “Surprise medical billing” occurs when a patient seeks care at an in-network...more

CMS Releases FY 2020 Medicare IPPS and LTCH PPS Proposed Rule and Proposes Key Changes to Several Regulatory Requirements

On April 23, 2019, CMS issued its annual Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System Proposed Rule for FY 2020 (the Proposed Rule), which will affect...more

Hospitals Challenge CMS’s Site-Neutral Payment Policies for Excepted Off-Campus Provider-Based Departments

On January 18, 2019, a group of nearly 40 hospitals filed a lawsuit in the United States District Court for the District of Columbia challenging CMS’s rate cut to evaluation and management (E/M) services furnished by excepted...more

CMS Releases Final 2019 Outpatient Prospective Payment System Rulemaking, Finalizing Site Neutral Payment Policy for Off-Campus...

On November 2, 2018, CMS issued the 2018 Hospital Outpatient Prospective Payment System (“OPPS”) Final Rule (“Final Rule”) in which it finalized its proposal to pay the lower Physician Fee Schedule (“PFS”) rate rather than...more

New Georgia Law Promotes Micro-Hospitals, Though CMS’s “Primarily Engaged” Standard Looms

On May 2, 2018, Georgia Governor Nathan Deal signed into law a bill allowing failed rural hospitals to be converted into “micro-hospitals.” The law comes as a response to a recent string of rural hospital closures and a...more

OIG Report Finds Many Outpatient Physical Therapy Services Did Not Comply With Medicare Requirements

Physical therapy providers are the target of a recent HHS Office of Inspector General (OIG) report that identified millions of dollars in overpayments for improperly billed Medicare services. The OIG selected a stratified...more

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