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Off-Campus Departments Administrative Authority

Baker Donelson

D.C. Appeals Court Upholds CMS's Authority to Limit Payment for E&M Services at Off-Site Provider-Based Locations

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The United States Court of Appeals for the District of Columbia recently upheld CMS's authority to expand site-neutral payment reductions for evaluation and management (E&M) services provided at longstanding off-campus...more

Baker Donelson

D.C. Court Rejects CMS's 2018 "Budget Neutrality" Policy

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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

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