A new federal law requires health care business entities to disclose personal information and photographs of persons with ownership and control over their business. The Centers for Medicare & Medicaid (CMS) and other federal...more
11/2/2023
/ Beneficial Owner ,
Business Ownership ,
Centers for Medicare & Medicaid Services (CMS) ,
Corporate Transparency Act ,
Disclosure Requirements ,
Financial Crimes ,
FinCEN ,
Health Care Providers ,
Healthcare ,
Regulatory Requirements ,
Reporting Requirements
The end of 2021 brings positive indications of the continued acceptance of telehealth as an important clinical care approach post public health emergency (“PHE”). The Centers for Medicare and Medicaid Services (“CMS”), like...more
2/22/2022
/ Ambulatory Surgery Centers ,
Centers for Medicare & Medicaid Services (CMS) ,
Drug Pricing ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
Inpatient Prospective Payment System (IPPS) ,
Medicaid ,
Medical Reimbursement ,
Medicare ,
Medicare Advantage ,
Outpatient Prospective Payment System (OPPS) ,
Payor Contracts ,
Physician Fee Schedule ,
Section 340B ,
Surprise Medical Bills ,
Telehealth
Less than one week after hearing oral arguments, the U.S. Supreme Court has stayed injunctions against the Centers for Medicare & Medicaid Services (“CMS”) Omnibus COVID-19 Health Care Staff Vaccination Rule (“Vaccine...more
1/14/2022
/ Biden Administration ,
Biden v Missouri ,
Centers for Medicare & Medicaid Services (CMS) ,
Constitutional Challenges ,
Coronavirus/COVID-19 ,
Employer Liability Issues ,
Employer Mandates ,
Essential Workers ,
Healthcare Workers ,
Infectious Diseases ,
Lack of Authority ,
Preliminary Injunctions ,
Stays ,
Vaccinations ,
Virus Testing ,
Workplace Safety
While the Centers for Medicare & Medicaid Services (“CMS”) Omnibus COVID-19 Health Care Staff Vaccination Rule (“CMS Vaccine Requirement”) heads to the Supreme Court, CMS will resume enforcement in the half of U.S. states not...more
12/31/2021
/ Biden Administration ,
Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Employer Liability Issues ,
Employer Mandates ,
Essential Workers ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Workers ,
Infectious Diseases ,
Preliminary Injunctions ,
Vaccinations ,
Workplace Safety
Two U.S. District Courts issued preliminary injunction orders this week barring CMS’ implementation of the Ominibus COVID-19 Health Care Staff Vaccination Rule (“CMS Vaccine Mandate”) on a nationwide basis. The CMS Vaccine...more
12/6/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Employer Liability Issues ,
Employer Mandates ,
Essential Workers ,
Healthcare Facilities ,
Healthcare Workers ,
Infectious Diseases ,
Preliminary Injunctions ,
Vaccinations ,
Workplace Safety
In the latest update to the fight surrounding vaccination of health care workers, the Centers for Medicare & Medicaid Services (“CMS”) announced that it suspended activities related to the implementation and enforcement of...more
12/6/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Employer Liability Issues ,
Employer Mandates ,
Essential Workers ,
Healthcare Facilities ,
Healthcare Workers ,
Infectious Diseases ,
Preliminary Injunctions ,
Vaccinations ,
Workplace Safety
The Centers For Medicare & Medicaid Services Issues New Inpatient Prospective Payment System Final Rule -
On September 3, 2020, the Centers for Medicare & Medicaid Services (CMS) issued the fiscal year (FY) 2021 Medicare...more
12/31/2020
/ Centers for Medicare & Medicaid Services (CMS) ,
Cramdown ,
Drug Pricing ,
Health Care Providers ,
Healthcare Reform ,
Inpatient Prospective Payment System (IPPS) ,
Medicaid ,
Medicare ,
Physician Fee Schedule ,
Physician Medicare Reimbursements ,
Section 340B ,
Telehealth ,
Value-Based Care
Introduction -
CMS has taken extensive measures to assist providers and promote access to care in light of the Public Health Emergency (PHE) related to the COVID-19 pandemic. The efforts taken have and continue to benefit...more
8/4/2020
/ Audits ,
CARES Act ,
Centers for Medicare & Medicaid Services (CMS) ,
COBRA ,
Coronavirus/COVID-19 ,
Health Care Providers ,
Health Insurance ,
Medicaid ,
Medical Reimbursement ,
Medicare ,
Skilled Nursing Facility ,
Telehealth ,
Telemedicine
Polsinelli is pleased to share The Privacy Survival Guide. This newsletter is a designated source of news, information and guidance on the constantly evolving health care privacy industry.
...more
The COVID-19 pandemic has created severe financial and operational difficulties for hospitals. Rapidly responding to a novel pathogen within a declared Public Health Emergency (PHE), while experiencing decreased revenues as a...more
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
...more
11/1/2019
/ Administrative Appeals ,
Centers for Medicare & Medicaid Services (CMS) ,
Contract Disputes ,
Enrollment ,
Health Care Providers ,
Injunctive Relief ,
Managed Care Contracts ,
Medical Reimbursement ,
Medicare ,
Payor Contracts ,
Revocation ,
Site-Neutral Exception ,
Universal Health Services Inc v United States ex rel Escobar
On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment Systems (“OPPS”) proposed rule [CMS-1717-P]. ...more
8/6/2019
/ Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Drug Pricing ,
General Authorization ,
Health Care Providers ,
Outpatient Prospective Payment System (OPPS) ,
Price Transparency ,
Proposed Rules ,
Rulemaking Process ,
Section 340B ,
Two-Midnight Rule
Polsinelli is pleased to share The Privacy Survival Guide. This newsletter is a designated source of news, information and guidance on the constantly evolving health care privacy industry.
...more
8/1/2019
/ Biometric Information ,
Biometric Information Privacy Act ,
California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Data Collection ,
Data Privacy ,
Electronic Medical Records ,
General Data Protection Regulation (GDPR) ,
Geolocation ,
Health Insurance Portability and Accountability Act (HIPAA) ,
International Data Transfers ,
Patient Privacy Rights ,
Personal Data ,
Personally Identifiable Information
On June 3, 2019, the Supreme Court issued an eagerly anticipated opinion in Azar v. Allina Health Services, a decision with far-reaching implications both for the calculation of disproportionate share payments and provider...more
7/10/2019
/ Administrative Procedure Act ,
Azar v Allina Health Services ,
Department of Health and Human Services (HHS) ,
Hospitals ,
Low-Income Issues ,
Medicare ,
Medicare Advantage ,
Medicare Part A ,
Medicare Part C ,
Notice and Comment ,
Pay Reductions ,
Provider Payments ,
Reaffirmation ,
Retroactive Application ,
SCOTUS ,
Substantive Rule ,
Vacated
Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry.
...more
On May 3, 2019, CMS published draft guidance regarding space sharing between co-located hospitals and hospitals co-located with other health care entities. ...more
On Wednesday July 25, 2018, the Centers for Medicare and Medicaid Services (CMS) released an advance copy of the CY 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. ...more
Hospitals with off-campus provider-based departments (“PBDs”) under construction (or “mid-build”) at the time of the Bipartisan Budget Act of 2015 – which limited Medicare payment to off-campus provider-based departments that...more
A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (off-campus PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build...more
2/8/2017
/ 21st Century Cures Act ,
Centers for Medicare & Medicaid Services (CMS) ,
Certification Requirements ,
Compliance Dates ,
Health Care Providers ,
Healthcare ,
Hospitals ,
Medicare ,
Medicare Administrative Contractors (MAC) ,
Off-Campus Departments ,
Outpatient Prospective Payment System (OPPS) ,
Professional Development
For relocations that occurred between 11.2.15 and 12.31.16, providers must submit relocation requests by 1.31.2017.
The CY 2017 OPPS Final Rule brought significant changes to the way Medicare reimburses hospitals for...more
CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”).
CMS revealed the changes on November 1...more
As part of the CY 2017 proposed Hospital Outpatient Prospective Payment System rules (OPPS) the Centers for Medicare and Medicaid Services (CMS) released the long awaited proposed payment changes for items and services...more
On Wednesday, members of the House Ways and Means Health Subcommittee introduced bipartisan legislation that would provide some welcome relief to hospitals who had already invested resources to develop new provider-based...more
On April 15, 2016, the Food and Drug Administration (FDA) released draft guidance that describes the FDA's interpretation of drug compounding standards under Sections 503A and 503B of the Food Drug & Cosmetic Act (FD&C Act)....more
Late last year, Congress made sweeping changes to Medicare provider-based reimbursement that virtually shut down any future off-campus, provider-based site developments. Section 603 of the Bipartisan Budget Act of 2015 (BBA)...more