Colleen Faddick on Centers for Medicare & Medicaid Services (CMS)

What the Health Care Industry Needs to Know About the Corporate Transparency Act

A new federal law requires health care business entities to disclose personal information and photographs of persons with ownership and control over their business. The Centers for Medicare & Medicaid (CMS) and other federal...more

11/2/2023 / Beneficial Owner , Business Ownership , Centers for Medicare & Medicaid Services (CMS) , Corporate Transparency Act , Disclosure Requirements , Financial Crimes , FinCEN , Health Care Providers , Healthcare , Regulatory Requirements , Reporting Requirements

Health Care Reimbursement and Payor Dispute Update Special Edition - Year End Regulatory Review

The end of 2021 brings positive indications of the continued acceptance of telehealth as an important clinical care approach post public health emergency (“PHE”). The Centers for Medicare and Medicaid Services (“CMS”), like...more

2/22/2022 / Ambulatory Surgery Centers , Centers for Medicare & Medicaid Services (CMS) , Drug Pricing , Health Care Providers , Health Insurance , Healthcare , Healthcare Reform , Inpatient Prospective Payment System (IPPS) , Medicaid , Medical Reimbursement , Medicare , Medicare Advantage , Outpatient Prospective Payment System (OPPS) , Payor Contracts , Physician Fee Schedule , Section 340B , Surprise Medical Bills , Telehealth

Supreme Court Keeps CMS Vaccine Requirement Alive Nationwide

Less than one week after hearing oral arguments, the U.S. Supreme Court has stayed injunctions against the Centers for Medicare & Medicaid Services (“CMS”) Omnibus COVID-19 Health Care Staff Vaccination Rule (“Vaccine...more

1/14/2022 / Biden Administration , Biden v Missouri , Centers for Medicare & Medicaid Services (CMS) , Constitutional Challenges , Coronavirus/COVID-19 , Employer Liability Issues , Employer Mandates , Essential Workers , Healthcare Workers , Infectious Diseases , Lack of Authority , Preliminary Injunctions , Stays , Vaccinations , Virus Testing , Workplace Safety

CMS Resumes Enforcement of Vaccine Requirement in Half of States

While the Centers for Medicare & Medicaid Services (“CMS”) Omnibus COVID-19 Health Care Staff Vaccination Rule (“CMS Vaccine Requirement”) heads to the Supreme Court, CMS will resume enforcement in the half of U.S. states not...more

12/31/2021 / Biden Administration , Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Employer Liability Issues , Employer Mandates , Essential Workers , Health Care Providers , Healthcare Facilities , Healthcare Workers , Infectious Diseases , Preliminary Injunctions , Vaccinations , Workplace Safety

Opponents of CMS Vaccine Mandate Secure Preliminary Injunctions Barring Nationwide Implementation

Two U.S. District Courts issued preliminary injunction orders this week barring CMS’ implementation of the Ominibus COVID-19 Health Care Staff Vaccination Rule (“CMS Vaccine Mandate”) on a nationwide basis. The CMS Vaccine...more

12/6/2021 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Employer Liability Issues , Employer Mandates , Essential Workers , Healthcare Facilities , Healthcare Workers , Infectious Diseases , Preliminary Injunctions , Vaccinations , Workplace Safety

CMS Vaccine Requirement Suspended During Injunctions

In the latest update to the fight surrounding vaccination of health care workers, the Centers for Medicare & Medicaid Services (“CMS”) announced that it suspended activities related to the implementation and enforcement of...more

12/6/2021 / Centers for Medicare & Medicaid Services (CMS) , Coronavirus/COVID-19 , Employer Liability Issues , Employer Mandates , Essential Workers , Healthcare Facilities , Healthcare Workers , Infectious Diseases , Preliminary Injunctions , Vaccinations , Workplace Safety

Health Care Reimbursement and Payor Dispute Update Special Edition – Year End Regulatory Review

The Centers For Medicare & Medicaid Services Issues New Inpatient Prospective Payment System Final Rule - On September 3, 2020, the Centers for Medicare & Medicaid Services (CMS) issued the fiscal year (FY) 2021 Medicare...more

12/31/2020 / Centers for Medicare & Medicaid Services (CMS) , Cramdown , Drug Pricing , Health Care Providers , Healthcare Reform , Inpatient Prospective Payment System (IPPS) , Medicaid , Medicare , Physician Fee Schedule , Physician Medicare Reimbursements , Section 340B , Telehealth , Value-Based Care

Health Care Reimbursement and Payor Dispute Update - August 2020

Introduction - CMS has taken extensive measures to assist providers and promote access to care in light of the Public Health Emergency (PHE) related to the COVID-19 pandemic. The efforts taken have and continue to benefit...more

8/4/2020 / Audits , CARES Act , Centers for Medicare & Medicaid Services (CMS) , COBRA , Coronavirus/COVID-19 , Health Care Providers , Health Insurance , Medicaid , Medical Reimbursement , Medicare , Skilled Nursing Facility , Telehealth , Telemedicine

Reimbursement and Payor Dispute Update -Federal Cases Offer Medicare-Enrolled Providers Possible Injunctive Relief from...

Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry. ...more

11/1/2019 / Administrative Appeals , Centers for Medicare & Medicaid Services (CMS) , Contract Disputes , Enrollment , Health Care Providers , Injunctive Relief , Managed Care Contracts , Medical Reimbursement , Medicare , Payor Contracts , Revocation , Site-Neutral Exception , Universal Health Services Inc v United States ex rel Escobar

CMS Takes Bold Action on Price Transparency & Physician Supervision in CY 2020 OPPS Proposed Rule

On July 29, 2019, the Centers for Medicare & Medicaid Services (“CMS”) released the CY 2020 Hospital Outpatient Prospective Payment Systems (“OPPS”) proposed rule [CMS-1717-P]. ...more

8/6/2019 / Centers for Medicare & Medicaid Services (CMS) , Comment Period , Drug Pricing , General Authorization , Health Care Providers , Outpatient Prospective Payment System (OPPS) , Price Transparency , Proposed Rules , Rulemaking Process , Section 340B , Two-Midnight Rule

Health Care Reimbursement and Payor Dispute Update - June 2019

Polsinelli is pleased to share the Health Care Reimbursement and Payor Dispute Update. This newsletter is a designated source of news, information and guidance on the constantly evolving reimbursement industry. ...more

6/21/2019 / Centers for Medicare & Medicaid Services (CMS) , Congressional Review Act , Deregulation , Draft Guidance , Health Care Providers , Healthcare Reform , Medical Reimbursement , OIRA , Regulatory Oversight , Regulatory Requirements

Space Sharing Re-Boot: CMS Offers a New Approach in the State Operations Manual

On May 3, 2019, CMS published draft guidance regarding space sharing between co-located hospitals and hospitals co-located with other health care entities. ...more

5/10/2019 / Centers for Medicare & Medicaid Services (CMS) , Comment Period , Conditions of Participation (CoP) , EMTALA , Health Care Providers , Healthcare Facilities , Hospitals , Regulatory Standards

CMS Targets Off-Campus Provider-Based Departments in 2019 OPPS Proposed Rule

On Wednesday July 25, 2018, the Centers for Medicare and Medicaid Services (CMS) released an advance copy of the CY 2019 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule. ...more

7/27/2018 / Centers for Medicare & Medicaid Services (CMS) , Data Collection , Health Care Providers , Hospitals , Medicare , Off-Campus Departments , Outpatient Prospective Payment System (OPPS) , Physician Medicare Reimbursements , Proposed Rules , Section 340B

Feb. 13 Deadline Looms for Provider-Based Departments Seeking Mid-Build Exception

A new section of the 21st Century Cures Act provides much-needed relief for hospitals with an off-campus provider-based department (off-campus PBD) that was mid-build or under development as of November 2, 2015 (the Mid-Build...more

2/8/2017 / 21st Century Cures Act , Centers for Medicare & Medicaid Services (CMS) , Certification Requirements , Compliance Dates , Health Care Providers , Healthcare , Hospitals , Medicare , Medicare Administrative Contractors (MAC) , Off-Campus Departments , Outpatient Prospective Payment System (OPPS) , Professional Development

Jan. 31 Deadline: Off-Campus Provider-Based Relocations Requests

For relocations that occurred between 11.2.15 and 12.31.16, providers must submit relocation requests by 1.31.2017. The CY 2017 OPPS Final Rule brought significant changes to the way Medicare reimburses hospitals for...more

1/30/2017 / Centers for Medicare & Medicaid Services (CMS) , Final Rules , Health Care Providers , Healthcare , Medicare , Off-Campus Departments , OPPS , Relocation

OPPS Provider-Based Final Rule — A More Practical Approach From CMS

CMS recently finalized sweeping changes to the way Medicare pays hospitals for services furnished in “new” off-campus provider-based departments (referred to as “off-campus PBDs”). CMS revealed the changes on November 1...more

11/28/2016 / Centers for Medicare & Medicaid Services (CMS) , EMTALA , FQHC , Health Care Providers , Healthcare , Hospitals , Medicare , MPFS , OPPS

CMS Proposes Amendments to Payments Furnished from Provider-Based Departments

As part of the CY 2017 proposed Hospital Outpatient Prospective Payment System rules (OPPS) the Centers for Medicare and Medicaid Services (CMS) released the long awaited proposed payment changes for items and services...more

7/13/2016 / Bipartisan Budget Act , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , OPPS , Outpatient Services , Physician Payments , Proposed Rules

Provider-Based Update: Congress Offers Encouraging Step to Reduce Scope of BBA Reimbursement Reductions

On Wednesday, members of the House Ways and Means Health Subcommittee introduced bipartisan legislation that would provide some welcome relief to hospitals who had already invested resources to develop new provider-based...more

5/24/2016 / Bipartisan Budget , Centers for Medicare & Medicaid Services (CMS) , Drug Pricing , Health Care Providers , Hospitals , Legislative Committees , Proposed Legislation , Reimbursements , Section 340B

Congress, CMS Seek Input on Provider-Based Reimbursement Reductions

Late last year, Congress made sweeping changes to Medicare provider-based reimbursement that virtually shut down any future off-campus, provider-based site developments. Section 603 of the Bipartisan Budget Act of 2015 (BBA)...more

2/23/2016 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , OPPS , Physician Medicare Reimbursements

60-Day Overpayment Reporting Final Rule—The Rule of Six

On February 12, 2016, CMS published the Reporting and Returning of Overpayments Final Rule (Final Rule). The Final Rule takes effect on March 14, 2016. Overall, CMS appears to have listened to stakeholders and acknowledged...more

2/16/2016 / 60-Day Rule , Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Medicare , Medicare Part A , Medicare Part B , Overpayment Recovery Time Limits

Provider-Based Status: A Quiet Casualty of the Bipartisan Budget Act

Without fanfare or any significant discussion, the Bipartisan Budget Act (Act) contains the first legislative action related to provider-based status—and it is a sweeping action with negative financial consequences to many...more

11/2/2015 / Bipartisan Agreement , Centers for Medicare & Medicaid Services (CMS) , Drug Pricing , Health Care Providers , Healthcare , Medicare , MedPAC , Obama Administration , OIG , OPPS , Pending Legislation , Pharmaceutical Industry , Physician Fee Schedule , Prescription Drugs , Section 340B

Health Reform + Related Health Policy News - December 2014, Issue 1

In This Issue: - Top News ..Congress Passes Omnibus Spending Package ..HRSA Cancels Plan for 340B ‘Mega Reg’; Congress Weighs Options ..Supreme Court to Hear Challenge to ACA...more

12/22/2014 / Affordable Care Act , Appropriations Bill , Centers for Medicare & Medicaid Services (CMS) , Halbig v Burwell , Healthcare , Healthcare Reform , Hospitals , HRSA , King v Burwell , Legislative Agendas , Medicare , Medicare Shared Savings Program , Physicians , SCOTUS , Section 340B , Subsidies

1/24/2014 / Affordable Care Act , Centers for Medicare & Medicaid Services (CMS) , Department of Health and Human Services (HHS) , EHR , Exempt Organizations , Health Insurance Portability and Accountability Act (HIPAA) , Healthcare , Healthcare Fraud , Healthcare Reform , Hospitals , Medicare , Misbranding , OCR , OIG , Prescription Drugs , Tax Exemptions

Colleen Faddick

Polsinelli

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