At long last, the Centers for Medicare and Medicaid Services (CMS) has issued decisions on provider applications for the mid-build exception. Nearly four years after the deadline for hospitals to apply for the mid-build...more
As promised, here is a summary of some key provisions in CMS’ proposed rule relating to the Medicare Advantage and Part D programs for contract years 2021 and 2022. CMS is soliciting comments on a number of issues and we urge...more
In a September 17, 2019 decision, the United States District Court for the District of Columbia invalidated a CMS rule expanding site-neutral payment reductions to evaluation and management (E&M) services furnished in...more
On September 17, 2019, the D.C. District Court held that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority when it cut the payment rate for clinic services at off-campus provider-based...more
In its Hospital Outpatient Prospective Payment System (OPPS) proposed rule, released July 29, 2019, the Centers for Medicare and Medicaid Service (CMS) proposes to finalize a two-year phase-in of site-neutral payment cuts for...more
• The Centers for Medicare & Medicaid Services (CMS) published the Calendar Year (CY) 2020 Proposed Rule for the Medicare Physician Fee Schedule (MPFS). The MPFS dictates Medicare rates and policies under Part B, while the...more
On July 11, 2019, the Centers for Medicare and Medicaid Services (CMS) issued its Home Health Prospective Payment System proposed rule for 2020. The proposed rule implements a previously finalized reimbursement methodology...more
CMS finalized a rule last month that will significantly expand access to telehealth services for patients in Medicare Advantage plans. Implementing provisions of the Bipartisan Budget Act of 2018 (BiBA), the new rule will...more
Last week, the Centers for Medicare and Medicaid Services (“CMS”) announced increased flexibility for Medicare Advantage health insurance plans to offer supplemental benefits (those benefits not covered under Medicare Parts A...more
The Centers for Medicare and Medicaid Services (CMS) recently released several significant Medicare Advantage (MA) and Part D guidance documents outlining new Center for Medicare and Medicaid Innovation (CMMI) programs and...more
CMS recently proposed several important changes for the Medicare Advantage ("MA") program that relate to payment, benefit design, and new actions to combat the opioid crisis. These changes, among others, were proposed in...more
As part of the 2019 Medicare Physician Fee Schedule Final Rule (Final Rule) published on November 23, 2018, the Centers for Medicare & Medicaid Services (CMS) took significant steps toward modernizing Medicare to expand...more
Part D Plan Sponsors’ Access to Medicare Parts A and B Claims Data Extracts - As detailed in previous posts in this series, one major objective that the Centers for Medicare and Medicaid Services (“CMS”) addressed in a...more
Requirements for MA Plans Offering Additional Telehealth Benefits - As part of the proposed rule issued November 1, 2018 by the Centers for Medicare and Medicaid Services (“CMS”) regarding updates to the Medicare Advantage...more
On October 26, 2018, the Centers for Medicare and Medicaid Services (“CMS”) released for viewing a proposed rule that includes significant changes for Medicare Advantage organizations (“MAOs”), Part D prescription drug plan...more
Hospitals, health systems, provider groups, and residential and community-based long-term care providers (collectively, “Providers”) should revisit their relationships with Medicare Advantage plans (“MA Plans”) in light of...more
The Centers for Medicare & Medicaid Services (“CMS”) recently proposed a major redesign of its Medicare Shared Savings Program (“MSSP”) under a new plan it calls “Pathways to Success.” In this Part II of the two-part series...more
On Aug. 9, 2018, Centers for Medicare and Medicaid Services (CMS) released a proposed rule that would update the Medicare Shared Savings Program (MSSP). Called "Pathways to Success," the proposal significantly alters the...more
The telemedicine industry was pleased to learn CMS recently proposed adding new services to its list of Medicare-covered telehealth services. But what may be more interesting are the services CMS declined to add, and why....more
On July 12, 2018, CMS issued proposed revisions to Year 3 of the Quality Payment Program (QPP) in the rule entitled Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019;...more
The Centers for Medicaid & Medicare Services (CMS) proposes to revise regulations issued pursuant to the Federal physician self-referrals Statute (Stark Law) to harmonize the regulations with the newly enacted Bipartisan...more
CMS recently published its proposed Medicare outpatient prospective payment system (OPPS) rule for calendar year (CY) 2019. The rule contains a number of "site-neutral" proposals that, if adopted, will result in lower...more
CMS has issued proposed payment rules for CY 2019 that hold significant implications for telehealth coverage and reimbursement. In the Proposed 2019 Home Health Prospective Payment System Rule (Proposed HH PPS Rule),...more
The Centers for Medicare and Medicaid Services (CMS) included two Stark Law clarifications in its proposed CY 2019 Physician Fee Schedule (Proposed Rule). The first change is with respect to the special rule for certain...more
Where Things Stood - Understanding the impact of what we have seen so far this year first requires an understanding of where we were at the end of 2017, with respect to both Medicare reimbursement and provider adoption of...more