AGG’s Home Health & Hospice team publishes a quarterly newsletter covering legal and regulatory topics specific to the home and community-based healthcare industry. The fields of end-of-life and home healthcare present business and regulatory challenges that require thoughtful legal approaches and experienced counsel. AGG represents publicly traded, privately held, and tax-exempt home health and hospice companies throughout the United States. We also provide advice to lenders and investors in the home health and hospice sectors. Our clients span the broad range of home and community-based services providers, for whom we provide counsel in corporate and transactional, compliance, audit, enrollment, survey and enforcement, reimbursement, fraud and abuse, privacy, litigation, real estate, and labor and employment matters.
In this edition, we discuss three recent actions by CMS. First, we examine CMS’ proposed revisions to the Medicare Provider Enrollment requirements to expand the current Home Health 36-Month Rule to hospice providers. Second, we address CMS’ period of “enhanced oversight” for new hospices in Arizona, California, Nevada, and Texas. Finally, we look at its new policies to identify and act against hospices believed to be engaged in fraud, waste, and abuse. We also highlight several of our AGG Healthcare attorneys’ articles and speaking engagements.
Featured Articles
CMS Proposes Expansion of 36-Month Rule to Include Hospice Providers
By Hedy S. Rubinger & Jessica T. Grozine
The Centers for Medicare & Medicaid Services (“CMS”) recently proposed revisions to the Medicare Provider Enrollment requirements to expand the current Home Health 36-Month Rule to hospice providers. If finalized, this expansion will have the potential to impact future hospice transactions and reorganizations.
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CMS Announces Enhanced Oversight for New Hospices in Four States
By Hedy S. Rubinger, Jessica T. Grozine, & Kadeja A. Watts
CMS recently announced that it will impose a period of “enhanced oversight,” in the form of medical review, for new hospices in Arizona, California, Nevada, and Texas. “New hospices” include newly enrolling hospices and those undergoing a change of ownership.
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CMS Addresses Benefit Integrity Issues Related to Hospice Care
By Lisa J. Churvis
CMS has adopted new policies to identify and act against hospices believed to be engaged in fraud, waste, and abuse. Measures put in place include nationwide site visits, enhanced medical review programs, and additional screening and monitoring methods.
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