News & Analysis as of

Hospitals Medicare OPPS

Cozen O'Connor

HHS Proposes $9 Billion Lump Sum Payment for Hospitals to Remedy Unlawful 340B Payment Reductions

Cozen O'Connor on

On Friday, July 7, 2023, the Centers for Medicare & Medicaid Services (CMS) published their long-awaited proposed remedy to the unlawful 340B drug payment reductions. Background: In 2018, CMS significantly reduced the...more

Baker Donelson

CMS Adopts Important "Site-Neutral" Changes to Payment Rules

Baker Donelson on

CMS took another step in its campaign to impose "site neutrality" on hospital outpatient payments with its recently published final Medicare hospital Outpatient Prospective Payment System (OPPS) rule for CY 2019. The final...more

Baker Donelson

CMS Proposes Major "Site-Neutral" Changes to Payments for Off-Campus Locations

Baker Donelson on

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

Bricker Graydon LLP

CMS proposes to limit the expansion of excepted services at off-campus PBDs

Bricker Graydon LLP on

On July 25, 2018, the Centers for Medicare & Medicaid Services (CMS) released the proposed Calendar Year (CY) 2019 Hospital Outpatient Prospective Payment (OPPS) Rule proposing, among other changes, to further restrict...more

Foley & Lardner LLP

Court Rules Against 340B Hospitals, Allows Medicare Reimbursement Cuts to Go Forward

Foley & Lardner LLP on

On Friday, December 29, 2017, the U.S. District Court for the District of Columbia dealt a blow to hospitals participating in the 340B Drug Pricing Program. By participating in the 340B program, eligible public and...more

Dorsey & Whitney LLP

New Medicare Proposals that Reduce Payment to Hospitals for 340B Drugs in 2018

Dorsey & Whitney LLP on

On July 13, 2017, CMS released several proposed rules impacting health care, including the 2018 Outpatient Prospective Payment System (OPPS) proposed rule which, among other proposals, could have a significant impact on 340B...more

Williams Mullen

CMS Issues Final Rule on Off-Campus Hospital Department Reimbursement

Williams Mullen on

As of January 1, 2017, hospitals will receive lower Medicare reimbursement for items and services provided at certain off-campus provider-based facilities. This Alert provides an overview of the new reimbursement framework...more

Polsinelli

OPPS Provider-Based Final Rule — A More Practical Approach From CMS

Polsinelli on

CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”). CMS revealed the changes on November 1...more

Stinson LLP

2017 OPPS Final Rule: Payment to Off-Campus Provider-Based Departments

Stinson LLP on

On November 1, 2016, the Centers for Medicare & Medicaid Services (CMS) issued the 2017 Medicare Outpatient Prospective Payment System (OPPS) Final Rule. One aspect of this rule is the implementation of payment decreases for...more

Foley & Lardner LLP

“Site Neutrality” for Off-Campus Outpatient Departments: Proposed Rule is Worse than You Expected!

Foley & Lardner LLP on

CMS issued its Outpatient Prospective Payment System (“OPPS”) Proposed Rule for 2017 (the “Proposed Rule”) on July 6, 2016. The Proposed Rule will be published in the Federal Register on July 14, 2016. One highly-anticipated...more

Baker Donelson

Proposed Provider-Based Changes Pose Significant Problems for Hospitals

Baker Donelson on

As we reported in a Payment Matters article last November 12, 2015, Section 603 of the Bipartisan Budget Act of 2015 changes the payment rules applicable to off-campus, provider-based locations that are new as of November 2,...more

McDermott Will & Emery

CMS Proposed Rule Implements Limitations on Medicare Payments for Off-Campus Outpatient Hospital Departments

McDermott Will & Emery on

In Depth - Background - On July 6, 2016, the Centers for Medicare & Medicaid Services (CMS) released the CY 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule, which includes proposed regulations to...more

Sheppard Mullin Richter & Hampton LLP

CMS Proposes to Limit Site Neutral Payment Exceptions Applicable to Certain Off-Campus Hospital Departments Following Relocation,...

On July 6, 2016, CMS released the 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule which, among other things, implements Section 603 of the Bipartisan Budget Act of 2015. Despite extensive lobbying efforts by...more

Foley & Lardner LLP

Legislation to Expand Definition of Grandfathered Off-Campus Hospital Departments to Address “Mid-Build” and Cancer Hospital...

Foley & Lardner LLP on

A bill amending the “site neutrality” limitations brought by Section 603 of the Bipartisan Budget Act of 2015 was introduced in the House of Representatives last week and passed out of committee yesterday. H.R. 5273, the...more

McDermott Will & Emery

Congress Considers Broader Hospital Site-Neutral Payment Exceptions and Other Payments Changes

McDermott Will & Emery on

In Depth - The House Ways and Means Committee next week is expected to consider and approve the Helping Hospitals Improve Patient Care Act of 2016, legislation that would create broader exceptions under much maligned...more

Parker Poe Adams & Bernstein LLP

Site Neutral Payments for Off-Campus Locations Established After Nov. 1, 2015

Provider-based off-campus hospital outpatient departments (OC-HOD’s) established after November 1, 2015 will be subject to a new site-neutral payment limitation starting Jan. 1, 2017 as a result of provisions in the Balanced...more

Dorsey & Whitney LLP

The Impact of the Bipartisan Budget Act of 2015 on Off-Campus Hospital Outpatient Departments

Dorsey & Whitney LLP on

On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015 (“Act”) into law significantly impacting how Medicare pays certain off-campus hospital departments. Specifically, Section 603 of the Act provides...more

Foley & Lardner LLP

Budget Law Moves Towards Site-Neutral Medicare Payments; Join Foley for a Discussion on November 13

Foley & Lardner LLP on

The recently enacted Bipartisan Budget Act (P. L. 114-74) included a provision that will significantly alter the future of hospital-based outpatient care. The provision, Section 603, will exclude from Medicare’s...more

McGuireWoods LLP

Budget Act Significantly Impacts Provider-Based Facility Reimbursement

McGuireWoods LLP on

On November 2, President Obama signed into the law the Bipartisan Budget Act of 2015 (the “Act”), which contains language that will significantly change how hospital-based outpatient care is reimbursed....more

King & Spalding

CMS Issues Final Rule for CY 2016 OPPS and Changes to the Two-Midnight Rule

King & Spalding on

On October 30, 2015, CMS issued its final rule with comment period (Final Rule) for the Medicare hospital outpatient prospective payment system (OPPS) and the Medicare ambulatory surgical center (ASC) payment system for...more

Proskauer Rose LLP

Budget Deal Alters Reimbursement to Off-Campus Hospital-Owned Facilities

Proskauer Rose LLP on

On November 2, 2015, President Obama signed into law H.R. 1314, the Bipartisan Budget Act of 2015 (the "Act"), which significantly changes Medicare reimbursement for off-campus hospital services. The Act, which Congress...more

Mintz - ML Strategies

Health Care Update - November 2015

Mintz - ML Strategies on

Ways & Means Leadership Changes – Health Policy Implications Looming: As Congress pushes forward with a two-year budget deal, and new Speaker Paul Ryan begins his tenure as the top Republican in the House of...more

King & Spalding

Budget Deal to Limit Provider-Based Status, Extend Sequestration

King & Spalding on

On October 28 and 30, 2015, the U.S. House of Representatives and U.S. Senate approved the Bipartisan Budget Act of 2015 (the Act)—a measure designed to raise the limit on Federal borrowing that would also have significant...more

King & Spalding

CMS Finalizes Significant Changes to the Two Midnight Rule in the 2016 OPPS Final Rule

King & Spalding on

On October 30, 2015, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year 2016 Outpatient Prospective Payment System Final Rule (2016 OPPS Final Rule). In the 2016 OPPS Final Rule, CMS finalizes...more

Stinson LLP

Reimbursement Change for Off-Campus Provider-Based Clinics, Physician Offices, and Ambulatory Surgical Centers

Stinson LLP on

On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015, a two-year budget deal with a key provision affecting hospitals and other health care providers. Effective January 1, 2017, the Act decreases the...more

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