Behind the Curtain: Enhanced Provider Enrollment Oversight
On March 28, the U.S. Departments of Health and Human Services, Labor and the Treasury collectively issued final rules with respect to short-term and limited duration insurance (STLDI) plans in an effort to reduce healthcare...more
Congress Returns Next Week to Face Imminent Funding Deadlines. The Senate will return to session on January 8, and the House will return on January 9. Lawmakers face an immediate time crunch on FY 2024 appropriations, as the...more
The US Centers for Medicare & Medicaid Services (CMS) finalized important changes to the Medicare provider and supplier enrollment regulations, including adding marriage and family therapists (MFTs) and mental health...more
The Centers for Medicare & Medicaid Services (“CMS”) continued its efforts to increase oversight of the Medicare program by updating Medicare provider enrollment regulations and policies through recent regulatory and...more
Medicare Advantage Organizations and Part D sponsors have a responsibility to ensure they offer and provide their members and potential enrollees with content and materials in alternate languages or accessible formats for...more
On August 28, 2023, OIG released a new webpage on managed care oversight, which features the HHS-OIG Strategic Plan for Oversight of Managed Care for Medicare and Medicaid. OIG has designated oversight of managed care as a...more
In our practices, we are seeing an increasing number of denials or de facto denials of Medi-Cal provider enrollments. The consequences of a Medi-Cal enrollment denial can be quite serious. First, a provider may not receive...more
The Centers for Medicare & Medicaid Services (“CMS”) published proposed changes to the Medicare Provider Enrollment requirements in the 2024 Medicare Physician Fee Schedule Proposed Rule (the “Proposed Rule”). If finalized,...more
On July 10, the Centers for Medicare & Medicaid Services (“CMS”) issued a Proposed Rule that would extend the “36-Month Rule” to Hospice providers. The 36-Month Rule refers to 42 C.F.R. § 424.550(b), which currently...more
On February 13, 2023, the Centers for Medicare & Medicaid Services (“CMS”) proposed a long-delayed regulation that would implement a provider enrollment provision of the Affordable Care Act that expands the information...more
In late January 2023, the Centers for Medicare and Medicaid Services (CMS) issued two updates relevant to provider and supplier organizations enrolled in Medicare: (1) a redesign to the Provider Enrollment, Chain and...more
On December 19, 2022, the U.S. Government Accountability Office (GAO) released a report titled, “Medicare: CMS Needs to Address Risks Posed by Provider Enrollment Waivers and Flexibilities” (GAO-23-105494). The report...more
On November 2, 2022, the Centers for Medicare & Medicaid Services (CMS) issued CY 2023 Physician Fee Schedule Final Rule (Final Rule), implementing certain updates and policy changes for Medicare payments under the Physician...more
The Affordable Care Act mandated that the Centers for Medicare and Medicaid Services (“CMS”) establish risk categories for Medicare enrollment, which are used by CMS to determine what level of scrutiny to give provider...more
The Centers for Medicare & Medicaid Services (CMS) requires Medicare providers and suppliers to keep their enrollment information up to date at all times. Changes in this information can affect claims processing, payment...more
Rural emergency hospitals (REHs) are a new Medicare provider type that will allow Medicare to pay for emergency department and other outpatient hospital services in rural areas beginning on January 1, 2023, without requiring...more
The Centers for Medicare and Medicaid Services (CMS) has started phasing out certain program flexibilities granted during the COVID-19 public health emergency. Beginning in October 2021, CMS will resume several provider and...more
Since the COVID-19 public health emergency was initiated in Arkansas in March 2020, Governor Asa Hutchinson has repeatedly renewed the emergency order, maintaining the public health emergency for fourteen (14) months. ...more
On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA) as part of a new (third) COVID-19 stimulus relief bill. ARPA assists qualifying individuals who lose coverage under an employer’s group...more
On March 11, 2021, President Biden signed into law the “American Rescue Plan Act” (“ARPA”) (HR 1319). While ARPA addresses many different areas, employers will need to act promptly with regard to benefits under the...more
The COVID-19 crisis is far from over, as evidenced by the 300,000 new U.S. cases reported over the past seven days. Recognizing this ongoing impact, federal and state officials have left in place many of the emergency...more
On May 22, 2020, CMS rolled out Transmittal 10146, which completely reorganizes existing Chapter 15 of the Medicare Program Integrity Manual (MPIM), CMS 100-08. These changes, effective July 24, 2020, implement the recent...more
To assist hospitals in credentialing physicians during the COVID-19 pandemic, the National Practitioner Data Bank (“NDPB”)—the federal clearinghouse for adverse action reports against physicians—has announced it is waiving...more
The Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services (HHS), the Office for Civil Rights (OCR), the Office of the Inspector General (OIG), and other Federal and State agencies and...more
With crisis comes uncertainty, and even the best-intentioned regulations can leave those combating the current COVID-19 public-health emergency out in the cold. Many have asked whether the recent Declaration under the...more