Centers for Medicare & Medicaid Services (CMS) released several pieces of Medicare provider enrollment guidance this spring, both emphasizing current policy and requirements as well as providing guidance and clarification...more
In May 2023, the Centers for Medicare and Medicaid Services (“CMS”) proposed a series of rule changes intended to help promote the availability of home and community-based services (“HCBS”) for Medicaid beneficiaries. Chief...more
The Centers for Medicare & Medicaid Services (“CMS”) continued its efforts to increase oversight of the Medicare program by updating Medicare provider enrollment regulations and policies through recent regulatory and...more
Recently the Centers for Medicare & Medicaid Services (“CMS”) announced in a newly released MedLearn Matter (MLN7867599, July 2023) that effective as of July 13, 2021, any “new hospice agency” located in the states of Texas,...more
The Centers for Medicare & Medicaid Services (“CMS”) published proposed changes to the Medicare Provider Enrollment requirements in the 2024 Medicare Physician Fee Schedule Proposed Rule (the “Proposed Rule”). If finalized,...more
On July 10, the Centers for Medicare & Medicaid Services (“CMS”) issued a Proposed Rule that would extend the “36-Month Rule” to Hospice providers.
The 36-Month Rule refers to 42 C.F.R. § 424.550(b), which currently...more
7/14/2023
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Change of Ownership ,
Comment Period ,
Enrollment ,
Healthcare ,
Healthcare Reform ,
Home Health Agencies ,
Hospice ,
Medicare ,
Proposed Rules ,
Public Comment
Co-Location and the Provider-Based Rules – No News is…Good News?
On July 15, the Centers for Medicare & Medicaid Services ("CMS") released the 2023 Outpatient Prospective Payment System proposed rule (“OPPS Proposed...more
9/15/2022
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Critical Access Hospitals ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
Medicare ,
No Surprises Act (NSA) ,
Outpatient Prospective Payment System (OPPS) ,
Payor Contracts ,
Surprise Medical Bills
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
On July 1, 2021, the Departments of Health and Human Services (“HHS”), Treasury, and Labor, along with the Office of Personnel Management (collectively the “Departments”), issued the first tranche of regulations implementing...more
9/30/2021
/ Biden Administration ,
Drug Pricing ,
Health Care Providers ,
Health Insurance ,
Healthcare Reform ,
Interim Final Rules (IFR) ,
Legislative Agendas ,
Medical Reimbursement ,
Out of Network Provider ,
Price Transparency ,
Provider Relief Fund ,
Regulatory Agenda ,
Surprise Medical Bills ,
Value-Based Care
The U.S. Department of Health & Human Services (HHS) released its highly anticipated Provider Relief Fund (PRF) reporting guidance on June 11, 2021, which outlines deadlines for providers to use the funding received and when...more
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
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
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
Hospitals with dangerously low inpatient volume and micro hospitals focused primarily on the delivery of outpatient and/or emergency room services instead of inpatient services beware: CMS (Centers for Medicare and Medicaid...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
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
On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged...more
Without fanfare or any significant discussion, the Bipartisan Budget Act (Act) contains the first legislative action related to provider-based status—and it is a sweeping action with negative financial consequences to many...more
11/2/2015
/ Bipartisan Agreement ,
Centers for Medicare & Medicaid Services (CMS) ,
Drug Pricing ,
Health Care Providers ,
Healthcare ,
Medicare ,
MedPAC ,
Obama Administration ,
OIG ,
OPPS ,
Pending Legislation ,
Pharmaceutical Industry ,
Physician Fee Schedule ,
Prescription Drugs ,
Section 340B