News & Analysis as of

Off-Campus Departments Physicians

McDermott+

Site Neutral Payment Considerations: Site-of-Service Patterns Vary by Geography

McDermott+ on

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

McGuireWoods LLP

D.C. Circuit Reversal Upholds CMS’ Site-Neutrality Cuts for Off-Campus Provider-Based Departments

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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

Bricker Graydon LLP

Federal court denies American Hospital Association review of CMS 2020 site-neutral payment cuts for hospital off-campus...

Bricker Graydon LLP on

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

Bricker Graydon LLP

CMS announces continuation of second year of site-neutral payment cuts

Bricker Graydon LLP on

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

Katten Muchin Rosenman LLP

Court Invalidates Latest CMS Effort to Reduce Reimbursement at Off-Campus Hospital Outpatient Departments

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

Brownstein Hyatt Farber Schreck

Court Vacates Rule That Lowered Medicare Payments to Off-Campus Clinics

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

Sheppard Mullin Richter & Hampton LLP

D.C. District Court Vacates CMS Final Rule, Finds that CMS’ Lesser Reimbursement of Services Provided at Grandfathered Off-Campus...

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

K&L Gates LLP

K&L Gates Triage: Activation of Validation Edits for OPPS Providers with Multiple Service Locations

K&L Gates LLP on

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

Robinson+Cole Health Law Diagnosis

2019 Physician Fee Schedule Rule Review: Off-Campus Provider-Based Hospital Departments

On November 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released a final rule (Rule), which includes modifications to Medicare payment policies and rates....more

Holland & Knight LLP

CMS Releases the 2019 OPPS and ASC Payment System Final Rule

Holland & Knight LLP on

• The Centers for Medicare & Medicaid Services (CMS) has issued the Calendar Year (CY) 2019 Final Rule that updates payment rates and policy changes in the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory...more

Holland & Knight LLP

CY 2019 OPPS Proposed Rule Extends Site Neutral Policies

Holland & Knight LLP on

On July 25, 2018, the Centers for Medicare & Medicaid Services (CMS) released proposed policy and payment updates affecting the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC)...more

K&L Gates LLP

CMS Issues Proposed Medicare PFS Rule for CY 2019

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On July 27, 2018, the Medicare Physician Fee Schedule (PFS) Proposed Rule for Calendar Year (CY) 2019 (PFS Proposed Rule) was published in the Federal Register....more

McGuireWoods LLP

2018 Reimbursement Cuts for Some Off-Campus Hospital Provider-Based Departments

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On Nov. 2, 2017, the Centers for Medicare and Medicaid Services (CMS) finalized a rule changing reimbursement rates under the Medicare Physician Fee Schedule (MPFS) for certain non-excepted hospital off-campus provider-based...more

Foley & Lardner LLP

Will the Massachusetts Proposed Legislation on Hospital Outpatient Facility Fees Have a Nationwide Impact?

Foley & Lardner LLP on

In some states, including the Commonwealth of Massachusetts, “site neutrality” for outpatient hospital reimbursement is factoring into state-specific health reform and cost containment initiatives. This potentially goes...more

King & Spalding

CMS Releases Proposed Rule for 2018 Physician Fee Schedule

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On July 13, 2017, CMS proposed a rule (Proposed Rule) updating payment policies and rates, as well as the quality provisions, for the Medicare Physician Fee Schedule (PFS). Among other provisions, the Proposed Rule reduces...more

Morgan Lewis

Provider-Based Rule and Stark—Is Joint Compliance Impossible in 2017?

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The Centers for Medicare & Medicaid Services (CMS) will be putting hospitals in an untenable position if recent proposed rulemaking is implemented as is. In its proposal for acting on legislation reducing payments to new,...more

BakerHostetler

Provider-Based Status Post-BBA: CMS Offers Limited Answers, Requests More Feedback

BakerHostetler on

For those in the hospital industry hoping for additional clarity regarding the operation and billing of provider-based departments (PBDs), the CY 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule provides some...more

Dorsey & Whitney LLP

CMS Issues Proposed Rule Addressing Off-Campus Outpatient Departments

Dorsey & Whitney LLP on

The Centers for Medicare and Medicaid Services (CMS) published its 2017 Medicare Outpatient Prospective Payment System (OPPS) proposed rule on July 14, 2016 (the Proposed Rule). In part, the Proposed Rule addresses CMS’s...more

King & Spalding

CMS Proposes Changes to Provider-Based Status in CY 2017 OPPS Rule - Agency takes aggressive view of Section 603 of Bipartisan...

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On July 6, 2016, the Centers for Medicare & Medicaid Services (CMS) issued its CY 2017 Outpatient Prospective Payment System (OPPS) Proposed Rule. The Proposed Rule includes several provisions regarding how CMS will...more

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