CMS Continues to Tighten the Belt on Hospital Off-Campus Provider-Based Departments

hospital

Hospitals with off-campus provider-based departments (PBDs) may want to rethink their end of summer vacation plans in order to focus on a recent slate of proposed regulations from the Center for Medicare and Medicaid Services (CMS) that seek to rein in Medicare reimbursement for outpatient hospital services – including at excepted/grandfathered off-campus locations.

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When Is Compensation Unreasonable?

cardiologist

Just what is reasonable compensation in the Medicare world is not a clearly defined, black and white concept. Instead, it is somewhat in the eye of the beholder, with the parties to each situation where that is an issue seeking to reach out for third party support for their conclusions. But sometimes when the government gets a chance to look at the conclusions, it is a “bridge too far.”

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Health Care Information Exchanges and Price Transparency Initiatives: CMS Requests Input from Providers

data mining

On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule introducing changes to the Medicare physician fee schedule, and soliciting comments from providers on CMS data sharing initiatives.  In the proposed rule, CMS requests comments on methods to promote the exchange of health care information between health care providers, and CMS initiatives to encourage price transparency for health care providers and suppliers. Continue reading this entry

The Association Health Plan Challenge: The States Initiate Litigation Challenging the Final Rule

government building

In our blog post of July 10, 2018, we discussed the key elements of the Final Rule issued on June 21, 2018 with respect to Association Health Plans (AHPs). As we noted, the expansion of ERISA’s definition of an employer and the other elements of the Final Rule designed to expand insurance opportunities for small employers, including sole proprietorships had been opposed by a variety of interests, including the Attorneys General of a number of States, some of whom promised litigation to stop the implementation of the Final Rule prior to the potential effective date of September 1, 2018 for fully insured AHPs.

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Medicare Proposes (and Rejects) New Telehealth Services for 2019

The telemedicine industry was pleased to learn CMS recently proposed adding new services to its list of Medicare-covered telehealth services.  But what may be more interesting are the services CMS declined to add, and why.  This article summarizes the newly-proposed additions as well as the services CMS rejected, explores some reasons for CMS’ decisions, and describes how industry advocates can submit comments to CMS and make their voice heard on these new proposals.  The public comment period is open through September 10, 2018.

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