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HHS Proposes Information Blocking Disincentives to Complement Existing Penalties

On Nov. 1, 2023, the Department of Health and Human Services (HHS), the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator (ONC) issued a proposed rule, the “21st Century Cures Act:...more

CMS Increases Oversight and Scrutiny of Hospices

In its continued effort to curb fraud and abuse in the hospice industry, on Aug. 22, 2023, the Centers for Medicare & Medicaid Services (CMS) announced it was making unannounced site visits to every Medicare-enrolled hospice...more

CMS Proposes 36-Month Rule for Medicare-Enrolled Hospices

The Centers for Medicare & Medicaid Services (CMS) proposed new rules intended to strengthen the integrity of the Medicare hospice enrollment process due to CMS’ view of fraud and abuse concerns in the hospice industry....more

CMS Publicly Releases Ownership Data for Medicare-Certified Hospice and Home Health Agencies

On April 20, 2023, the Centers for Medicare & Medicaid Services (CMS) announced the release of ownership data for all Medicare-enrolled hospice and home health agencies. This release is consistent with the Department of...more

End of COVID-19 Emergency: Legal Implications for Healthcare Providers

On Jan. 30, 2023, President Joe Biden announced that the COVID-19 public health emergency (PHE) will end May 11, 2023. Under the PHE, the federal government implemented a range of modifications and waivers impacting Medicare,...more

Outdated Medicare Enrollment Data? Caution: CMS Verifying Ownership

In recent weeks, the Centers for Medicare & Medicaid Services (CMS) has been contacting certain Medicare-enrolled providers and suppliers (hereinafter “providers”) to verify that their ownership information, as reported in...more

CMS Vaccine Mandate Enforcement Begins — Understanding the Three Deadlines

On Jan. 13, 2022, the U.S. Supreme Court permitted the Centers for Medicare & Medicaid Services (CMS) to enforce its interim final rule requiring many Medicare- and Medicaid-certified providers and suppliers to vaccinate...more

Supreme Court Upholds CMS Vaccine Mandate: Next Steps for Healthcare Providers

Update (Jan. 15, 2022): After the Jan. 14, 2022, publication of this alert, the Centers for Medicare & Medicaid Services issued updated guidance to State Survey Agency directors providing 30 days (by Feb. 13) for facilities...more

Takeaways From New CMS Interim Rule Requiring COVID-19 Vaccination for Healthcare Providers and Suppliers

As McGuireWoods noted in a Sept. 10, 2021, alert, in Sept. 20 and Sept. 23 FAQs, and in Sept. 27 and Oct. 18 alerts, President Biden’s “Path Out of the Pandemic” employee COVID-19 vaccination mandates have three main...more

CMS Accelerated and Advance Payment Recoupment Begins

Recoupment has started or will soon begin for Medicare Part A and Part B providers and suppliers who received funds in 2020 under the Medicare Accelerated and Advance Payment (AAP) Program. The Centers for Medicare & Medicaid...more

CMS Updates Medicare Accelerated and Advance Program Repayment Guidance and Start Date

The Centers for Medicare & Medicaid Services (CMS) recently issued an updated fact sheet and a FAQ page detailing the repayment terms for Medicare Part A providers and Part B suppliers who received payments under its...more

CMS Suspends Advance Payments and Re-evaluates Accelerated Payments

On April 26, 2020, the Centers for Medicare & Medicaid Services (CMS) announced it was immediately suspending its advance payment program to Part B suppliers, and re-evaluating the amounts that will be paid to providers under...more

“Hospitals Without Walls” and Other Flexibilities for Hospitals During COVID-19

On March 31, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule with comment period (IFC). This alert is part of a series of alerts discussing the IFC provisions and comprehensive actions...more

CMS Waives Certain Requirements to Expand Healthcare Workforce, Put Patients Over Paperwork

As part of its continued efforts to ease burdens on healthcare providers during the 2019 novel coronavirus (COVID-19) pandemic, the Centers for Medicare & Medicaid Services (CMS) released a slew of additional waivers on March...more

CMS Eases Healthcare Provider Enrollment Process in Response to COVID-19 Crisis

As the 2019 novel coronavirus (COVID-19) pandemic continues to strain the healthcare industry, the Centers for Medicare & Medicaid Services (CMS) eased healthcare provider enrollment rules. CMS has significantly streamlined...more

HHS Acts to Support Telehealth Services in Response to COVID-19: Six Key Takeaways

The unprecedented public health emergency created by the coronavirus disease (COVID-19) has sparked action by the U.S. government to ensure greater access to healthcare via telehealth services, especially for high-risk...more

CMS Issues Long-Awaited Guidance on Hospital Co-Location Policy

On May 3, 2019, the Centers for Medicare & Medicaid Services (CMS) issued draft guidance formalizing the agency’s policy on hospital co-location with other hospitals and healthcare entities. CMS’ new policy walks back its...more

CMS Provides Waivers in States Affected by Hurricanes Harvey and Irma

September 20, 2017 The Centers for Medicare & Medicaid Services (CMS) recently modified and waived certain Medicare enrollment and billing requirements to ensure the availability of adequate medical care for Medicare...more

CMS Open Payments: A Look Behind the Curtain

Compliance officers often lament that it is impossible to identify, assess and manage the compliance risks of financial relationships they know nothing about. Too often they are limited to relationships brought to their...more

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