HealthLaw HotSpot - A Look at Alternative Reimbursement Models in Value-Based Care
Jones Day Talks Health Care: The Eliminating Kickbacks in Recovery Act
Value-based health care: fraud & abuse laws
Tax Developments Affecting Health Care Organizations and Investor-Owned Hospital Companies
Within its proposed CY 2025 Physician Fee Schedule (PFS) rule (the Proposed Rule), CMS is proposing to implement new payment policies intended to advance health equity and support whole-person care. CMS expects these new...more
The Centers for Medicare & Medicaid Services (CMS) announced a new primary care model—the Making Care Primary (MCP) Model—geared towards smaller, independent primary care practices and organizations that want to participate...more
The Centers for Medicare & Medicaid Services (“CMS”) recently published the proposed 2023 Physician Fee Schedule (“PFS”), which contains several important changes affecting Accountable Care Organizations (“ACOs”) that...more
As part of the CY 2023 Physician Fee Schedule proposed rule (the Proposed Rule) released on July 7, 2022, CMS has proposed significant changes to the Medicare Shared Savings Program (MSSP). The agency’s press release...more
On April 27, 2021, CMS issued the fiscal year (FY) 2022 proposed rule for the hospital inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment system (the Proposed Rule). Among...more
On August 11, 2020, the CMS Innovation Center, the office within HHS with authority to create and test healthcare payment systems, announced a new payment model – the Community Health Access and Rural Transformation (CHART)...more
On April 30, the Centers for Medicare & Medicaid Services (CMS) announced numerous regulatory waivers and rule changes to, among other things, expand Medicare beneficiaries’ access to coronavirus testing and telehealth...more
The ACO Specialist Manual is a strategic guide to getting the optimum value-add contributions from each medical specialty in integrated health care. For purposes of this Manual, the teams are generally termed accountable care...more
On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released its 2019 Physician Fee Schedule Final Rule (PFS Rule), which contains a number of significant substantive changes to Medicare payment practices...more
On August 17, 2018, the Centers for Medicare & Medicaid Services (“CMS”) officially published a proposed rule (“Proposed Rule”) in the Federal Register that would significantly alter the Medicare Shared Savings Program...more
The Centers for Medicare & Medicaid Services (CMS) published a proposed rule on August 17, 2018, that would make sweeping changes to the Medicare Shared Savings Program (MSSP), a federal program that incentivizes integrated...more
The Bipartisan Budget Act of 2018 recently introduced three noteworthy program improvements for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP) aimed at increasing program...more
On December 15, 2016, HHS announced an Accountable Care Organization (ACO) initiative for beneficiaries who are dually eligible for Medicare and Medicaid. The Medicare-Medicaid ACO Model (Model) builds on the Medicare Shared...more
On the heels of the release of its final rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA), the Centers for Medicare and Medicaid Services (CMS) released its 2017 list of Advanced Alternative Payment...more
Since the Affordable Care Act was enacted, many providers have been shifting away from traditional fee-for-service, volume-based reimbursement models to payment mechanisms that take a data-driven approach to managing patients...more
Better Late Than Never: CMS Provides Much-Needed Clarity on the 60-Day Overpayment Refund Requirements - On February 12, 2016, the Centers for Medicare & Medicaid Services (CMS) issued the long-awaited final rule (Final...more
On Thursday, October 29, 2015, the Centers for Medicare & Medicaid Services (“CMS”) and the Office of Inspector General (“OIG”) jointly issued a rule (the “Final Rule”) to finalize five (5) waivers of certain fraud and abuse...more
Trends & Analysis - Since our last Qui Tam Update, we have identified 39 health-related False Claims Act (“FCA”) qui tam cases that have been unsealed. Of those cases...more
On July 8, 2015, CMS issued its annual proposed rule outlining payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) for CY 2016. In the proposed rule,...more
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 fourth post in Health Care Law Today’s series on the final rule. This post addresses how CMS assigns beneficiaries to an ACO participating in the MSSP. In the MSSP ACO Final Rule, CMS finalized new...more
In This Issue: - ACO Eligibility Requirements - Establishing and Maintaining the ACO Participation Agreement - Data Sharing and Assignment of Beneficiaries - Shared Savings and Losses - Waivers of...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
Last week, the Centers for Medicare & Medicaid Services (CMS) released its Final Rule on the Medicare Shared Savings Program (MSSP). The Final Rule provides additional flexibility to accountable care organizations...more
The most recent Shared Savings Program final rule, published in the Federal Register on June 9, 2015, finalizes a number of the revisions to the original November 2011 final rule that CMS proposed on December 8, 2014. In...more