K&L Gates Triage: 340B Regulatory Update: CMS Proposal and Draft Executive Order Could Have Big Impact on 340B Program
K&L Gates Triage: 340B Eligibility - Hospital Covered Entities
Last week, the Centers for Medicare & Medicaid Services (CMS) released the two major regulations we all were waiting for: the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) proposed reg and the CY 2024 Outpatient...more
Rural emergency hospitals (REHs) are a new provider type that will allow Medicare to pay for emergency department and other outpatient hospital services in rural areas beginning on January 1, 2023, without requiring the...more
Beginning in 2023, Medicare will recognize a new provider type: the Rural Emergency Hospital (REH). The establishment of REHs is intended to preserve access to emergency departments and other outpatient services in rural...more
Compliance Today (March 2021) - The Centers for Medicare & Medicaid Services (CMS) has provided the following compliance notice: “In a recent report, the Office of Inspector General (OIG) determined that Medicare made...more
In its Hospital Outpatient Prospective Payment System (OPPS) proposed rule, released July 29, 2019, the Centers for Medicare and Medicaid Service (CMS) proposes to finalize a two-year phase-in of site-neutral payment cuts for...more
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
2017 was another challenging year for hospitals grappling with site-neutral payment changes for off-campus provider-based hospital outpatient departments (OCPBDs). ...more
Acute care hospitals that provide Medicare outpatient services to inpatients of other hospitals should be billing and collecting payment from the other inpatient hospitals and not from Medicare....more
In the recently published proposed rule related to the CY 2018 Hospital Outpatient Prospective Payment System (OPPS), the Centers for Medicare & Medicaid Services (CMS) announced that it is considering changes to the...more
CMS recently proposed to reduce the facility fee for non-excepted off-campus provider-based hospital departments (OPBDs) from 50 percent of the Medicare Physician Fee Schedule (MPFS) amount to 25 percent of the MPFS amount....more
In a proposed rule published in the Federal Register on July 21, 2017, the Centers for Medicare & Medicaid Services (“CMS”) moved to cut payments for most services provided by off-campus locations of hospitals by 50 percent. ...more
The 21st Century Cures Act (the “Cures Act”) (Pub. L. No. 114-255), which was signed into law by President Obama on December 13, 2016, includes a number of important health care provisions, and several address the...more
On May 24, 2016, the U.S. House Ways and Means Committee approved legislation that would continue Hospital Outpatient Prospective Payment System (OPPS) payment for off-campus provider-based departments that were “mid-build”...more
Included in its publication announcing changes for outpatient therapy services in the 2016 Medicare Physician Fee Schedule (MPFS), CMS announced a new requirement for Medicare-certified outpatient therapy providers (e.g.,...more
On October 30, 2015, CMS issued its final policy changes, quality provisions and payment rates for the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for...more