R. Christopher Raphaely on Medicare

CMS Releases Final Stark Rules To Promote Value-Based Care

On Friday, November 20, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released final regulations to remove certain barriers to the implementation of physician compensation arrangements under value-based payment...more

11/24/2020 / Centers for Medicare & Medicaid Services (CMS) , Compensation , Final Rules , Health Care Providers , Medicaid , Medicare , Physicians , Stark Law , Value-Based Payments

Pharma Price Disclosure Rule Struck Down: Will Hospital Price Transparency Rule Meet The Same Fate?

On June 16, the D.C. Circuit Court struck down the Centers for Medicare and Medicaid Services’ (“CMS”) rule issued in May 2019 requiring pharmaceutical companies to disclose the wholesale acquisition cost of drugs over $35 in...more

6/22/2020 / Affordable Care Act , American Hospital Association , Centers for Medicare & Medicaid Services (CMS) , Medicaid , Medicare , Pharmaceutical Industry , Transparency , Trump Administration

CMS Releases Final ACO Regulations

This morning CMS released a final rule regarding its most popular program for accountable care organizations (ACOs), the Medicare Shared Savings Programs. The final rule is based on the proposed rule for the program that was...more

12/24/2018 / ACOs , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Medicare Shared Savings Program , Proposed Rules

The Medicare Shared Savings Program and the New Glide Path to Risk

With the first class of 82 Accountable Care Organizations (ACO) in the Medicare Shared Savings Program (MSSP) awaiting word on what the future holds for their participation in the program after January 1, 2019, the Centers...more

8/24/2018 / ACOs , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Medicare Shared Savings Program

Futures in Doubt of CMS’ New Mandatory Bundled Payment Models and Medicare Shared Savings Program Track 1+

Word spread quickly Monday (December 20, 2016) about CMS’ issuance of final regulations (to be published in the Federal Register on January 3, 2017) rolling out new mandatory bundled payments models for Acute Miocardial...more

12/27/2016 / Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , Incentives , Medicare , Medicare Access and CHIP Reauthorization (MACRA) , Medicare Shared Savings Program

Ignorance Is Not Bliss: The 60-Day Clock under the ACA’s “Return and Report Rule” Can Start Ticking Well Before the Exact Amount...

On August 3, 2015, a federal judge in the Southern District of New York ruled that the United States’ and state of New York’s complaints in intervention can move forward against a group of hospitals, under the federal False...more

8/6/2015 / Affordable Care Act , False Claims Act (FCA) , Hospitals , Intervenors , Medicaid , Medicare , Mistake , Motion to Dismiss , Overpayment , Overpayment Recovery Time Limits , Qui Tam , Relators , Software

Next Generation ACOs: CMMI Doubles Down on the Two-Sided Risk ACO Model

While one part of the Affordable Care Act, exchange subsidies, hangs in the balance with the Supreme Court’s upcoming decision in King v Burwell, CMS is moving forward aggressively with the evolution of a less controversial...more

3/18/2015 / ACOs , Affordable Care Act , CMMI , Healthcare , Medicare , Medicare Shared Savings Program

HHS Ups The Ante: Announces Percentages And Time Frames On Goals For Medicare Pay-For-Value Efforts

On January 26, 2015, the Secretary of the United States Department of Health and Human Services (“HHS”), Sylvia Mathews Burwell, announced two important goals for the Department...more

1/28/2015 / Affordable Care Act , Department of Health and Human Services (HHS) , Fee-for-Service , Healthcare , Medicare , Provider Payments

CMS Releases New Proposed Medicare Shared Savings Program Regulations

The Centers for Medicare and Medicaid Services (“CMS”) released proposed regulations for the Medicare Shared Savings Program (“MSSP”) on Monday December 1, 2014. The proposed regulations are scheduled to be published in the...more

12/4/2014 / ACOs , Centers for Medicare & Medicaid Services (CMS) , Healthcare , Medicare , Medicare Shared Savings Program , Proposed Regulation

IRS Releases Guidance on Private Business Use, and ACOs and Management Contracts

On October 25, 2014, the Internal Revenue Service (the IRS) released Notice 2014-67 that provides interim guidance on (i) participation in the Medicare Shared Savings Program through an accountable care organization (ACO) and...more

11/5/2014 / ACOs , Centers for Medicare & Medicaid Services (CMS) , Healthcare , IRS , Medicare , Medicare Shared Savings Program

ACOs And Pay for Value … About the Data

It has been over three years since the Centers for Medicare and Medicaid Services (CMS) announced its proposed rule and guidance on the development and implementation of Accountable Care Organizations. About four million...more

7/25/2014 / ACOs , Centers for Medicare & Medicaid Services (CMS) , Health Insurance Portability and Accountability Act (HIPAA) , Healthcare , Medicaid , Medicare , Patient Privacy Rights , Risk Assessment , Risk Management , Rulemaking Process

R. Christopher Raphaely

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