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CMS Spring Provider Enrollment Updates

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

The 80/20 Rule is Here: CMS Finalizes HCBS Care Worker Payment Requirements

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

Medicare Continues its Updates to Provider Enrollment Policies as Part of Efforts to Enhance Program Integrity and Transparency

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

CMS Announces Period of Enhanced Oversight for New Hospices in Arizona, California, Nevada, and Texas

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

CMS Proposes Changes to Medicare Provider Enrollment Rules

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

“36-Month Rule” Anticipated to Expand to Hospice

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

Health Care Reimbursement and Payor Dispute Update - September 2022

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

Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review

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

Health Care Reimbursement and Payor Dispute Update - August 2020

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

Health Care Reimbursement and Payor Dispute Update - June 2019

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

Space Sharing Re-Boot: CMS Offers a New Approach in the State Operations Manual

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

CMS Targets Off-Campus Provider-Based Departments in 2019 OPPS Proposed Rule

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

Hospital Medicare Certification at Risk? CMS Clarifies Inpatient Volume Expectations

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

CMS Proposes Amendments to Payments Furnished from Provider-Based Departments

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

Provider-Based Update: Congress Offers Encouraging Step to Reduce Scope of BBA Reimbursement Reductions

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

Congress, CMS Seek Input on Provider-Based Reimbursement Reductions

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

60-Day Overpayment Reporting Final Rule—The Rule of Six

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

Provider-Based Status: A Quiet Casualty of the Bipartisan Budget Act

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

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