Site neutral payment proposals are currently a key topic among policymakers. This +Insight explores how Medicare fee-for-service (FFS) site-of-service patterns vary across states and metropolitan statistical areas (MSAs). Our...more
On May 17, the House Energy and Commerce Committee Health Subcommittee held a markup of 17 healthcare bills. In particular, the subcommittee advanced legislation that would implement site-neutral payments under Medicare for...more
The U.S. Department of Justice (the “DOJ”) recently settled whistleblower False Claims Act (“FCA”) allegations against The University of Miami (“UMiami”) for $22 million, which resolves claims from three separate lawsuits...more
Report on Medicare Compliance 30, no. 2 (January 18, 2021) - CMS is taking back money from hospitals for outpatient clinic visits provided in 2019 at excepted off-campus provider-based departments (PBDs) after returning...more
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
The U.S. Court of Appeals for the D.C. Circuit recently reversed a district court ruling and upheld the Centers for Medicare & Medicaid Services site-neutrality payment cuts for off-campus outpatient hospital clinic visits....more
On March 24, 2020, the Centers for Medicare & Medicaid Services (CMS) announced a delay until further notice to the activation of systematic validation edits for OPPS providers with multiple locations. After multiple prior...more
A Medicare Administrative Contractor (MAC) recently sent letters to some Medicare participating hospitals asking them to verify their hospital practice locations based on the information the MAC has from the hospital’s...more
On Thursday, February 20, 2020, hospitals represented by King & Spalding that operate excepted off-campus provided-based outpatient departments (PBDs) filed their brief in federal appeals court to preserve the victory they...more
CMS and its contractors have announced that beginning January 1, 2020, the agency will repay hospitals for underpaid evaluation and management (E/M) services provided in excepted off-campus provider-based departments during...more
On December 16, 2019, the U.S. District Court for the District of Columbia ruled that its 2019 decision invalidating the Center for Medicare and Medicaid Services’ (CMS) site-neutral payment cuts does not automatically vacate...more
CMS’ 340B Rate Cut Continues to Dampen Hospital Outpatient Expansion Efforts - Hospitals hoping to benefit from favorable 340B drug pricing when acquiring independent physician practices for conversion to hospital...more
n November 1, 2019, CMS posted the final rule establishing the payment rates for the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgery Center (ASC) Payment System for calendar year (CY) 2020...more
Despite a court ruling against its site-neutral policy in September 2019, in the Calendar Year (CY) 2020 Medicare Outpatient Prospective Payment System (OPPS) final rule, released on November 1, 2019, the Centers for Medicare...more
Late last week, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment System (“OPPS”) final rule [CMS-1717-FC]. While many hospitals had hoped for relief from recent...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
Key Points - ·On September 17, 2019, the District Court for the District of Columbia rejected the Centers for Medicare and Medicaid Services’ (CMS) latest attempt to limit Medicare reimbursement at off-campus outpatient...more
On September 17, 2019, the US District Court for the District of Columbia ruled in American Hospital Association, et al. v. Alex Azar, II, et al that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory...more
On Sept. 17, 2019, a Washington, D.C. district court judge ruled that the Centers for Medicare & Medicaid Services (CMS) “exceeded its statutory authority when it cut the payment rate for clinic services at off-campus...more
On September 17, 2019, U.S. District Judge Rosemary M. Collyer of the U.S. District Court for the District of Columbia awarded summary judgment in favor a group of more than 40 hospitals on their challenge to CMS’s decision...more
Hospitals can breathe (at least temporarily) a sigh of relief as the U.S. District Court for the District of Columbia determined that the Centers for Medicare & Medicaid Services (CMS) exceeded its statutory authority when it...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
On September 17, 2019, the U.S. District Court for the District of Columbia ruled against the Centers for Medicare and Medicaid Services (“CMS”), vacating CMS’ 2018 Final OPPS Rule, which cut Medicare reimbursement rates for...more
On September 17, 2019, the United States District Court for the District of Columbia ruled that the Center for Medicare and Medicaid Services (CMS) exceeded its authority and failed to follow the statutory process for setting...more
The Centers for Medicare and Medicaid Services (CMS), recently announced that it plans to activate systematic validation edits for Outpatient Prospective Payment System (OPPS) providers with multiple service locations that...more