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Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review

The Centers For Medicare & Medicaid Services Issues New Inpatient Prospective Payment System Final Rule - On September 3, 2020, the Centers for Medicare & Medicaid Services (CMS) issued the fiscal year (FY) 2021 Medicare...more

Health Care Reimbursement and Payor Dispute Update - August 2020

Introduction - CMS has taken extensive measures to assist providers and promote access to care in light of the Public Health Emergency (PHE) related to the COVID-19 pandemic. The efforts taken have and continue to benefit...more

Remote Patient Monitoring Opportunities and Risks for Technology Vendors and Providers

In recent years, the Centers for Medicare and Medicaid Services (CMS) has expanded coverage for remote patient monitoring (RPM) services under Medicare. RPM services include establishing, implementing, revising, and...more

CMS Issues New Final Rule on Pricing Transparency

On November 15, CMS issued the Price Transparency Requirements for Hospitals to Make Standards Charges Public Final Rule (“Final Rule”), as directed by President Donald Trump’s Executive Order on Improving Price and Quality...more

CMS Takes Bold Action on Price Transparency & Physician Supervision in CY 2020 OPPS Proposed Rule

On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment Systems (“OPPS”) proposed rule [CMS-1717-P]. ...more

Space Sharing Re-Boot: CMS Offers a New Approach in the State Operations Manual

On May 3, 2019, CMS published draft guidance regarding space sharing between co-located hospitals and hospitals co-located with other health care entities. ...more

CMS Targets Off-Campus Provider-Based Departments in 2019 OPPS Proposed Rule

On Wednesday July 25, 2018, the Centers for Medicare and Medicaid Services (CMS) released an advance copy of the CY 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. ...more

Be Prepared: Provider-Based Mid-Build Audits Are Here

Hospitals with off-campus provider-based departments (“PBDs”) under construction (or “mid-build”) at the time of the Bipartisan Budget Act of 2015 – which limited Medicare payment to off-campus provider-based departments that...more

The More Things Change, the More They Stay the Same – CMS’ Guidance on Co-Located Hospitals and the Removal of Certain Hospital...

With recent changes to the Hospital within Hospital (“HwH”) rules, is it easier to meet the HwH standards? Likely, not. HwHs are hospitals excluded from the inpatient prospective payment system (“IPPS”), such as psychiatric,...more

Feb. 13 Deadline Looms for Provider-Based Departments Seeking Mid-Build Exception

A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (off-campus PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build...more

Jan. 31 Deadline: Off-Campus Provider-Based Relocations Requests

For relocations that occurred between 11.2.15 and 12.31.16, providers must submit relocation requests by 1.31.2017. The CY 2017 OPPS Final Rule brought significant changes to the way Medicare reimburses hospitals for...more

60-Day Overpayment Reporting Final Rule—The Rule of Six

On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged...more

CMS Proposes Overhaul of Clinical Lab Payment Methodology: What You Need To Know

On Friday, the Centers for Medicare & Medicaid Services (“CMS”) issued a long-awaited proposed rule that would drastically change the payment rates for clinical laboratory services beginning January 1, 2017 (the “Proposed...more

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