News & Analysis as of

Off-Campus Departments 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

McGuireWoods LLP

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

McGuireWoods LLP on

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

Bricker Graydon LLP

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

Bricker Graydon LLP on

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

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

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

Bricker Graydon LLP on

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

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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