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HHS Proposes to Halt Further Delays of 340B Oversight and Enforcement Rules

The Department of Health and Human Services (“HHS”) has proposed to accelerate the implementation of regulatory changes designed to protect hospitals from being overcharged for drugs purchased under the 340B Drug Pricing...more

CMS Begins Audits of Worksheet S-10 for FY 2015 Cost Reports

In the Inpatient Prospective Payment System (IPPS) rulemaking for fiscal year (FY) 2019, the Centers for Medicare and Medicare Services (CMS) announced that it would begin auditing the charity care and bad debt costs...more

D.C. Circuit Clears the Way for Hospitals to Challenge Base-Year Factual Determinations

The United States Court of Appeals for the District of Columbia Circuit recently held in Saint Francis Medical Center v. Azar that Medicare’s reopening regulation, which prohibits providers from seeking to revise payment...more

CMS Issues New Instructions for Completing Worksheet S-10 and Extends Deadline for Providers to Submit Updated Data for FYs 2014...

For the second time in less than one year, CMS has updated its instructions for completing Worksheet S-10 of the Medicare cost report for hospitals. The new instructions expand the definition of charity care, as reported in...more

CMS’s Interim Final Rule to Permit “Stacking” of Reclassifications Puts Pressure on Urban Hospitals to Evaluate Advantages of...

Hospitals may seek redesignation to a neighboring core-based statistical area for wage index purposes under the rules that set forth the geographic reclassification process. See 42 C.F.R. § 412.230 et seq. Those rules...more

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