We previously noted that the regulations implementing the No Surprises Act (“NSA”) appeared to be inconsistent with the NSA because they seemed to establish the qualifying payment amount (“QPA”) as the appropriate payment...more
8/31/2022
/ Billing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Health Care Providers ,
Health Insurance ,
Healthcare Facilities ,
Hospitals ,
Interim Final Rules (IFR) ,
No Surprises Act (NSA) ,
U.S. Treasury
In a November 12, 2021 revision of its prior draft guidelines for hospital co-location compliance with Medicare conditions of participation (COP) for hospitals (QSO-19-13), CMS has apparently softened its approach to...more
Although the COVID-19 pandemic is still active worldwide, health care industry leaders and regulators have already begun to think about how to implement post-pandemic changes to health care delivery based on lessons learned...more
10/27/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Coronavirus/COVID-19 ,
Disaster Preparedness ,
Emergency Management Plans ,
Health Care Providers ,
Healthcare Facilities ,
Hospitals ,
Infectious Diseases ,
Patient Access ,
Personal Protective Equipment ,
Public Health Emergency ,
Telehealth
In a FAQ published on August 20, 2021, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) significantly delayed implementation of statutory requirements on surprise billing...more
9/3/2021
/ Affordable Care Act ,
Consolidated Appropriations Act (CAA) ,
Delays ,
Health Care Providers ,
Health Insurance ,
Healthcare Reform ,
Hospitals ,
Price Transparency ,
Public Disclosure ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Requirements ,
Surprise Medical Bills
As discussed in a prior post, the Hospital Price Transparency Rule at 45 C.F.R. § 180.10 et. seq. (the “Rule”), requires all hospitals to provide clear, accessible pricing information about the items and services they provide...more
In a prior blog post, we discussed CMS’ Hospital Price Transparency Rule at 45 C.F.R. § 180.10 et. seq., effective January 1, 2021 (the “Rule”), which requires hospitals to make public “a machine-readable file containing a...more
In a report issued by the Office of the Inspector General (OIG) at the Department of Health and Human Services (HHS) on March 23, 2021 (the “2021 Report”), representatives from 320 hospitals in 45 states, the District of...more
This post is part one of two in a series on new transparency requirements impacting both health plans and health care providers.
In an effort to assist patients in understanding the cost of hospital services, the Hospital...more
As promised, this is a follow-up to our first blog post on the new federal transparency requirements. In our prior post, we summarized the Hospital Price Transparency rule which went into effect on January 1, 2021, and here...more
The recently enacted Consolidated Appropriations Act, 2021 (the “Act”) not only funds the government and provides further relief in regard to the impact of the COVID-19 pandemic, but it also adopted a number of new...more
On November 2, 2015, President Obama signed into law H.R. 1314, the Bipartisan Budget Act of 2015 (the "Act"), which significantly changes Medicare reimbursement for off-campus hospital services. The Act, which Congress...more
11/5/2015
/ Barack Obama ,
Congressional Budget Office ,
Federal Budget ,
Health Care Providers ,
Healthcare ,
Hospitals ,
Medicare ,
New Legislation ,
OPPS ,
Physician Fee Schedule ,
Reimbursements
On August 7, 2014, Judge Castel of the Southern District of New York dismissed a False Claims Act (“FCA”) complaint that was based primarily on allegations that the defendant Hospital improperly focused on referral revenue in...more