News & Analysis as of

Provider Payments

OIG Finds Acute Care Hospitals Improperly Billed for Outpatient Services Provided to Inpatients of Other Hospitals

by Baker Ober Health Law on

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

SuperVision - Labor & Employment Law Insights - September 2017

...This issue of SuperVision is dedicated to questions our friends and clients may have regarding insurance and benefit topics. While not a common part of the Labor & Employment field, Spilman prides itself on having...more

CMS Proposes New Payment Model and Other Changes for Home Health Agencies

by Bass, Berry & Sims PLC on

Among the various payment updates proposed by the Centers for Medicare and Medicaid Services (CMS) this summer, the proposed payment update for the home health agency prospective payment system (HHA-PPS), published in the...more

CMS Proposes to Cancel EPM and CR Bundled Payment Programs and to Reduce Mandatory Participation in CJR Model

The Centers for Medicare and Medicaid Services (CMS) recently published a proposed rule (Proposed Rule) to scale back its mandatory bundled payment programs. Under the Proposed Rule, CMS would cancel the episode payment...more

Health Alert (Australia) 4 September 2017

by DLA Piper on

In This Issue: - Judgments; Legislation; and Reports. - Excerpts from Judgments: 30 August 2017 - Australian Competition and Consumer Commission v Medibank Private Limited [2017] FCA 1006 - In this proceeding,...more

Medicare Payments for Telehealth Increased 28% in 2016: What You Should Know

by Foley & Lardner LLP on

Telehealth providers can celebrate another successful year of growth, as CMS reported a 28% increase over total 2016 payments for telehealth services under the Medicare program. Providers continue to successfully integrate...more

Mandatory Cardiac Episode Payment Program: CMS Proposes Cancellation

by Foley & Lardner LLP on

On August 15, 2017, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (Proposed Rule) that, if finalized, would (1) reduce the number of Metropolitan Statistical Areas (MSAs) in which there is...more

CMS Aims to Nix Obama-Era Payment Models

In a proposed rule published Tuesday, August 15, 2017, the Centers for Medicare & Medicaid Services (CMS) announced its intention to roll back a handful of payment models introduced under the Obama Administration. If...more

CMS Merely Soliciting Comments on Including Total Joints as ASC Procedures

by Tucker Arensberg, P.C. on

CMS released the proposed update for the Hospital Outpatient Perspective Payment System and the Ambulatory Surgery Center System on July 13, 2017, and the release has generated some unexpected controversy regarding the...more

Hospitals Plagued by HHS's 2012 Medicare DSH Calculation Obtain Relief from the D.C. Circuit

by Baker Ober Health Law on

Hospitals affected by HHS's 2014 decision to include Medicare Part C enrollees as part of the Medicare fraction of the disproportionate share calculation obtained relief late last month when that position was voided by the...more

CMS revises CJR program, cancels cardiac bundles

by Thompson Coburn LLP on

On Aug. 15, 2017, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule seeking to reduce mandatory participation requirements in the Comprehensive Care for Joint Replacement (CJR) program for hospitals...more

CMS Cancels EPM and Cardiac Rehabilitation Incentive Program While Revising CJR in New Proposed Rule

by Baker Ober Health Law on

After initially delaying the implementation of Episode Payment Models (EPMs) earlier this year, CMS issued a Proposed Rule on August 17 that proposes to cancel all EPMs and the Cardiac Rehabilitation Incentive Program (CR)...more

CMS Proposes to Cancel Bundled Payment and Incentive Models

The U.S. Centers for Medicare & Medicaid Services (CMS) published a proposed rule last week regarding the cancellation of three bundled payment models and an incentive payment model while also reducing the scope of a third...more

CMS Proposal Terminates and Revises Mandatory Bundled Payment Models

by Polsinelli on

On August 15, 2017, the Centers for Medicare & Medicaid Services (CMS) announced a proposed rule which would cancel the Episode Payment Models (EPMs) and the Cardiac Rehabilitation (CR) incentive payment model, each of which...more

CMS May Decide to Permit Labs to Bill for Certain Tests Provided to Outpatients

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 Extends Comment Period for New SNF PPS Methodology Proposal

by Baker Ober Health Law on

On May 4, for the first time in nearly 15 years, CMS issued an Advanced Notice of Proposed Rulemaking (ANPRM) proposing a total overhaul of the current reimbursement methodology for skilled nursing facilities (SNFs). The...more

CMS Proposes QPP Revisions: The Paths for QPP Participation Continue to Evolve

by Baker Ober Health Law on

CMS recently proposed modified policies for continued implementation of the Quality Payment Program (QPP) in the 2017 Proposed Rule. Among other things, the Proposed Rule provides flexibility for clinicians in the second QPP...more

CMS Proposes to Reduce Facility Payment for Non-Excepted Provider-Based Outpatient Department Services by 50 Percent

by Baker Ober Health Law on

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

CMS Releases Proposed 2018 Medicare Payment Regulations

by Baker Ober Health Law on

On July 13, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2018 Physician Fee Schedule that would update payment policies, payment rates and quality provisions for physicians and other medical...more

New “Site Neutrality” Proposed Rule Would Slash Hospital Outpatient Payments for Off-Campus Services by 50%

by Seyfarth Shaw LLP on

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

Is Telemedicine Change Coming to Congress? The Medicare Telehealth Parity Act of 2017 Among Several New Federal Bills

by Foley & Lardner LLP on

Congress is reconsidering a nationwide telehealth coverage bill, named the Medicare Telehealth Parity Act of 2017, designed to introduce an incremental, though significant, expansion of coverage for telehealth services under...more

"Locum Tenens" Physical Therapist – Does the Change Provide Sufficient Relief?

by Baker Ober Health Law on

CMS recently published guidance to implement Section 16006 of the 21st Century Cures Act, effective June 13, 2017, which allows physical therapists providing services to Medicare beneficiaries to utilize "locum tenens"...more

CMS Releases the Final Medicare Part D DIR Reporting Requirements for 2016

On Friday, June 23, 2017, CMS released the Final Medicare Part D DIR Reporting Requirements for 2016. Part D sponsors may begin submitting their DIR information on June 30, 2017 and must finish their submissions by the end of...more

CMS Releases MACRA Proposed Rule for 2018

by Baker Ober Health Law on

On June 20, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule entitled, "Medicare Program; CY 2018 Updates to the Quality Payment Program." CMS proposes changes for the second year (2018) of the...more

Are you subject to MIPS reporting requirements in 2017?

by Thompson Coburn LLP on

The Centers for Medicare and Medicaid Services (“CMS”) announced in late April that they anticipated notifying eligible clinicians about their Merit-based Incentive Payment System (“MIPS”) participation status for 2017 via...more

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