News & Analysis as of

Healthcare Payment Plans

Mintz - Employment, Labor & Benefits...

The Affordable Care Act—Countdown to Compliance for Employers, Week 30: The IRS Tells Us that Employer Payment Plans (Really,...

The IRS recently issued two Q&As on the subject of employer payment plans, the purpose of which was to again underscore that arrangements purporting to allow an employer to reimburse employees on a pre-tax basis for premiums...more

McDermott Will & Emery

New Guidance Clarifies Health Reimbursement Arrangements Under ACA

McDermott Will & Emery on

Recently issued guidance clarifies the application of certain provisions under the Affordable Care Act (ACA) to health reimbursement arrangements, employer payment plans, health flexible spending arrangements and employee...more

Morgan Lewis

Guidance on the Application of Certain ACA Market Reforms to Employer Health Plans

Morgan Lewis on

Plan sponsors should review their health reimbursement arrangements, employer payment plans, health flexible spending arrangements, and employee assistance programs to ensure they comply with ACA market reforms....more

Baker Donelson

CMS Proposes FQHC Prospective Payment System

Baker Donelson on

On September 23, 2013, CMS published a proposed rule to overhaul the payment methodology for federally qualified health centers (FQHCs). The proposed rule will change FQHC reimbursement from an all inclusive rate (AIR),...more

King & Spalding

CMS Publishes Correction to OPPS/ASC Proposed Rule

King & Spalding on

On September 6, 2013, CMS published in the Federal Register a correction to its previously published annual Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule for calendar...more

Baker Donelson

CMS to Begin Implementing 25 Percent Threshold for LTCHs

Baker Donelson on

CMS, in its federal fiscal year (FFY) 2014 final rule, has allowed its five-year moratorium on the 25 percent threshold payment adjustment policy to expire. Following the lifting of this moratorium, LTCHs that admit more than...more

Baker Donelson

IPPS Final Rule: CMS Addresses Allina Decision and Addresses New Medicare DSH Payment Calculations

Baker Donelson on

In the fiscal year 2014 Inpatient Prospective Payment System (IPPS) rule published in the Federal Register on August 19, 2013, CMS took two steps of note regarding the Medicare disproportionate share hospital (DSH)...more

King & Spalding

CMS Releases FY 2011 SSI Ratios

King & Spalding on

CMS has released the FY 2011 SSI data for IPPS hospitals, LTCHs, and IRFs. This data will be used to determine the disproportionate share adjustment for hospitals and the low-income payment adjustment for IRFs for cost...more

King & Spalding

CMS Releases FY 2014 Hospital IPPS Final Rule

King & Spalding on

On August 2, 2013, CMS released the annual Hospital Inpatient Prospective Payment System Final Rule for FY 2014 (the “Final Rule”), effective for discharges occurring on or after October 1, 2013....more

King & Spalding

DC Circuit Issues Latest DSH Decision, Reducing Reimbursements

King & Spalding on

On June 11, 2013, the D.C. Circuit Court issued the latest ruling relating to the proper calculation of hospitals’ disproportionate share hospital (DSH) payment, leading to potentially lower Medicare reimbursements related to...more

Baker Donelson

CMS Proposes FY 2014 Payment Rates and Policies for Medicare Inpatient Rehabilitation Facilities

Baker Donelson on

On May 2, 2013, CMS released a proposed rule [PDF] for the Inpatient Rehabilitation Facility Prospective Payment System for fiscal year (FY) 2014. The proposed rule sets forth Medicare payment policies and rates governing...more

BakerHostetler

Bringing Sunlight to Healthcare Pricing: The CMS Release of Hospital Charge Data

BakerHostetler on

Former U.S. Supreme Court Justice Louis D. Brandeis once said that "Sunlight is the best disinfectant." The release of charges billed by some 3,337 Medicare hospitals for 100 of the most common inpatient diagnosis related...more

Baker Donelson

OIG Updates Special Advisory Bulletin on the Effect of Exclusion from Federal Health Programs

Baker Donelson on

On May 8, 2013, the OIG issued an update that supersedes and replaces its 1999 Special Advisory Bulletin, The Effect of Exclusion from Participation in Federal Health Care Programs. The updated bulletin continues to stress...more

Morgan Lewis

OIG Revises Special Advisory Bulletin on Exclusions

Morgan Lewis on

OIG continues its aggressive interpretation of scope and effect of exclusion from participation in Federal health care programs and clarifies several open questions....more

Baker Donelson

The New DSH - Are You Supplying The Correct Data That Will Drive Your Payments?

Baker Donelson on

Effective October 1, 2013, CMS will begin paying disproportionate share hospitals differently. Congress ordered the change to the disproportionate share hospital (DSH) adjustment payment methodology as part of the Patient...more

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