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Centers for Medicare & Medicaid Services (CMS) Site-Neutral Exception

McDermott+

Site Neutral Payment Considerations: Site-of-Service Patterns Vary by Geography

McDermott+ on

Site neutral payment proposals are currently a key topic among policymakers. This +Insight explores how Medicare fee-for-service (FFS) site-of-service patterns vary across states and metropolitan statistical areas (MSAs). Our...more

McDermott+

Impact of Site Neutral Payment Proposals May Vary in Rural and Urban Populations

McDermott+ on

Introduction- Site neutral payment proposals may affect access differently across patient populations. In this +Insight, we focus on how site-of-service patterns for drug administration services, which both the Medicare...more

Sheppard Mullin Richter & Hampton LLP

Site-Neutral Payments Stand: SCOTUS Declines to Hear AHA Appeal, Preserving Lower Payments to Off-Campus Provider-Based...

In July 2020, we discussed a ruling by the D.C. Court of Appeals upholding the Department of Health and Human Services’ (HHS) site-neutral payment rules. On Monday, June 28, 2021, the Supreme Court declined, without comment,...more

Sheppard Mullin Richter & Hampton LLP

Forthcoming Medicare Rule Furthers Push for Site Neutrality

On December 2, 2020, the Centers for Medicare & Medicaid Services (“CMS”) finalized policies that “aim to increase choice, lower patients’ out-of-pocket costs, empower patients, and protect taxpayer dollars” with changes to...more

McGuireWoods LLP

D.C. Circuit Reversal Upholds CMS’ Site-Neutrality Cuts for Off-Campus Provider-Based Departments

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The U.S. Court of Appeals for the D.C. Circuit recently reversed a district court ruling and upheld the Centers for Medicare & Medicaid Services site-neutrality payment cuts for off-campus outpatient hospital clinic visits....more

Sheppard Mullin Richter & Hampton LLP

Site-Neutral Payments Stand: D.C. Court of Appeals Overturns Ruling and Allows Lower Payments to Off-Campus Provider-Based...

On July 17, 2020, in a blow to health care providers, the U.S. Court of Appeals for the D.C. Circuit overturned a lower court’s more favorable ruling and held that the Department of Health and Human Services (“HHS”)...more

Bricker Graydon LLP

Federal court denies American Hospital Association review of CMS 2020 site-neutral payment cuts for hospital off-campus...

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On December 16, 2019, the U.S. District Court for the District of Columbia ruled that its 2019 decision invalidating the Center for Medicare and Medicaid Services’ (CMS) site-neutral payment cuts does not automatically vacate...more

Robinson+Cole Health Law Diagnosis

CMS to Repay Hospitals Millions After Court Finds Reduction in Rates Improper

On December 12, 2019, the Centers for Medicare and Medicaid Services (CMS) announced that it will automatically reprocess claims which had been reimbursed at a reduced rate in 2019 under the site-neutral payment policy and...more

Foley & Lardner LLP

Massachusetts Governor Proposes Facility Fee Ban

Foley & Lardner LLP on

Massachusetts Governor Charlie Baker has restarted the discussion on health care cost containment in the Commonwealth with a proposed bill that contains a raft of initiatives. This is the first in a series of blog posts to...more

Bricker Graydon LLP

CMS announces continuation of second year of site-neutral payment cuts

Bricker Graydon LLP on

Despite a court ruling against its site-neutral policy in September 2019, in the Calendar Year (CY) 2020 Medicare Outpatient Prospective Payment System (OPPS) final rule, released on November 1, 2019, the Centers for Medicare...more

Polsinelli

Reimbursement and Payor Dispute Update -Federal Cases Offer Medicare-Enrolled Providers Possible Injunctive Relief from...

Polsinelli on

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

Katten Muchin Rosenman LLP

Court Invalidates Latest CMS Effort to Reduce Reimbursement at Off-Campus Hospital Outpatient Departments

Key Points - ·On September 17, 2019, the District Court for the District of Columbia rejected the Centers for Medicare and Medicaid Services’ (CMS) latest attempt to limit Medicare reimbursement at off-campus outpatient...more

Bricker Graydon LLP

Federal court invalidates CMS site-neutral payment cuts for hospital off-campus provider-based locations

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On September 17, 2019, the United States District Court for the District of Columbia ruled that the Center for Medicare and Medicaid Services (CMS) exceeded its authority and failed to follow the statutory process for setting...more

King & Spalding

Hospitals Challenge CMS’s Site-Neutral Payment Policies for Excepted Off-Campus Provider-Based Departments

King & Spalding on

On January 18, 2019, a group of nearly 40 hospitals filed a lawsuit in the United States District Court for the District of Columbia challenging CMS’s rate cut to evaluation and management (E/M) services furnished by excepted...more

Baker Donelson

CMS Adopts Important "Site-Neutral" Changes to Payment Rules

Baker Donelson on

CMS took another step in its campaign to impose "site neutrality" on hospital outpatient payments with its recently published final Medicare hospital Outpatient Prospective Payment System (OPPS) rule for CY 2019. The final...more

Bricker Graydon LLP

CMS finalizes site-neutral payment for clinic visits but declines to finalize clinical families payment limitation

Bricker Graydon LLP on

In its final Calendar Year (CY) 2019 Outpatient Prospective Payment System (OPPS) Rule released November 2, 2018 (the Final Rule), the Centers for Medicare & Medicaid Services (CMS) finalized its proposal to make payments for...more

Holland & Knight LLP

CY 2019 OPPS Proposed Rule Extends Site Neutral Policies

Holland & Knight LLP on

On July 25, 2018, the Centers for Medicare & Medicaid Services (CMS) released proposed policy and payment updates affecting the Hospital Outpatient Prospective Payment System (OPPS) and the Ambulatory Surgical Center (ASC)...more

Seyfarth Shaw LLP

New “Site Neutrality” Proposed Rule Would Slash Hospital Outpatient Payments for Off-Campus Services by 50%

Seyfarth Shaw LLP on

In a proposed rule published in the Federal Register on July 21, 2017, the Centers for Medicare & Medicaid Services (“CMS”) moved to cut payments for most services provided by off-campus locations of hospitals by 50 percent. ...more

Foley & Lardner LLP

21st Century Cures Act Provides Some Welcome Relief

Foley & Lardner LLP on

The 21st Century Cures Act (the “Cures Act”) (Pub. L. No. 114-255), which was signed into law by President Obama on December 13, 2016, includes a number of important health care provisions, and several address the...more

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