On March 4, 2024, CMS issued Ruling 1498-R3 which revokes CMS Ruling 1498-R2. CMS Ruling 1498-R2 gave providers the option of using either “total” days or “covered” days in calculating their disproportionate share (DSH)...more
Last week, the Supreme Court released a decision relating to how the Department of Health and Human Services (HHS) requires hospitals to calculate its disproportionate share percentage. While this percentage is primarily used...more
Helpful hints - OIG Updates Health Care Fraud Self-Disclosure Protocol (“SDP”) - On November 8, 2021, the OIG issued an updated SDP to providers, which included clarifications of existing guidance and increased the minimum...more
Last week, the United States Court of Appeals for the District of Columbia Circuit upheld the ruling of a federal district court vacating HHS’s 2004 Disproportionate Share Hospital (“DSH”) rule regarding Part C days. The...more
In the fiscal year 2014 Inpatient Prospective Payment System (IPPS) rule published in the Federal Register on August 19, 2013, CMS took two steps of note regarding the Medicare disproportionate share hospital (DSH)...more
A number of recent developments affecting the Disproportionate Share Hospital (DSH) percentage calculation methodologies will likely have significant impact on 340B covered entities. DSH hospitals that participate in the 340B...more
In late night action on December 31, 2012, the American Taxpayer Relief Act of 2012 (ATRA) was passed by the Senate and finalized days later by Congress and the President with a set of tax and spending policy provisions...more