CMS Posts Recovery Audit Contractor Program Update, Including Reduced Documentation Request Limits – On November 6, 2015, CMS posted updates regarding the Recovery Audit Contractor (RAC) program, including a new additional documentation request (ADR) limit of 0.5 percent of a facility’s total number of paid Medicare claims from the previous year, effective January 1, 2016. The announcement from CMS and full list of RAC program changes are available here.
CMS Seeks Comments on Medicare Access and CHIP Reauthorization Act of 2015 Episode Groups – As required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), CMS is soliciting comments regarding patient care episode groups. Comments are due by February 15, 2016. More information is available here.
King & Spalding Forming Client Coalition to Advance Stark Reforms – King & Spalding provides a wide range of Stark law advice to our hospital industry clients. We have heard from you that the current state of Stark enforcement is unsustainable; the complexity of the Stark rules promotes confusion, not clarity; technical violations and missteps lead to excessive fines and penalties; and recent judicial interpretations of the Stark rules diverge from CMS guidance and what should be acceptable business practices. CMS has recently acknowledged the need to reform some Stark rules, but the agency lacks legal authority to make the most meaningful changes. Policymakers in Washington are interested in hearing about Stark legislative reforms from those most affected by the Stark rules. King & Spalding believes the time is ripe to consider another approach to Stark: advocating for sensible Stark law reforms. Please contact Mark Polston at mpolston@kslaw.com or Rob Keenan at rkeenan@kslaw.com to obtain additional information about the goals of this new coalition and how to join.
King & Spalding Makes Prior Roundtable Discussing Options for Dealing with Competitors Illegally Gaining Business Advantages Available As On-Demand Webinar – As the result of popular demand, King & Spalding has made available as an on-demand webcast the roundtable originally presented on Tuesday, October 20, 2015, titled, “Unlevel Playing Field: What Can You Do When Your Competitor Is Gaining an Illegal Advantage?” The webinar is free of charge and will be available until December 15, 2015. For additional information and to register for the event, please click here.
