Last week, the Government Accountability Office (GAO) published a report determining that there is a nontrivial risk that prior authorization requirements, together with internal coverage criteria, may undermine the Medicare...more
On Friday, April 11, 2025, CMS issued its annual Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) Proposed Rule for Fiscal Year (FY) 2026 (the Proposed...more
4/22/2025
/ Centers for Medicare & Medicaid Services (CMS) ,
Healthcare ,
Healthcare Facilities ,
Hospitals ,
Inpatient Prospective Payment System (IPPS) ,
Long-Term Care ,
Medicare ,
Payment Systems ,
Proposed Rules ,
Prospective Payment System (PPS) ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process
On December 18, 2024, a bipartisan group of four Senators on the Senate Finance Committee released draft legislation that would expand the total number of Medicare Graduate Medical Education (GME) full-time equivalent (FTE)...more
1/23/2025
/ Centers for Medicare & Medicaid Services (CMS) ,
Consolidated Appropriations Act (CAA) ,
Health Care Providers ,
Healthcare ,
Hospitals ,
Legislative Agendas ,
Medicare ,
Mental Health ,
New Legislation ,
Physicians ,
Proposed Legislation
On December 11, 2024, the Texas Health and Human Services Commission filed a complaint in the United States District Court for the Western District of Texas. The complaint seeks to block the enforcement of a May 9, 2014,...more
On November 20, 2024, OIG released new compliance program guidelines for nursing facilities titled, “Nursing Facility Industry Segment-Specific Compliance Program Guidance” (the Nursing Facility ICPG or the Guidance). The...more
12/2/2024
/ Anti-Kickback Statute ,
Billing ,
Compliance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Medicaid ,
Medicare ,
New Guidance ,
OIG ,
Patient-Driven Payment Model (PDPM) ,
Popular ,
Prospective Payment System (PPS) ,
Quality of Care Standards ,
Self-Referral ,
Skilled Nursing Facility
On August 15, 2024, the United States District Court for the Northern District of Texas vacated a Medicare regulation excluding from the Medicare DSH payment days attributable to inpatients covered by a section 1115 waiver...more
On August 1, 2024, CMS filed a display copy of its final rule for Fiscal Year (FY) 2025 pertaining to the Inpatient Prospective Payment Systems (IPPS) for general acute care hospitals and long-term care hospitals (LTCHs) (the...more
On June 28, 2024, the Supreme Court issued a decision in Loper Bright Enterprises v. Raimondo that overturned the Chevron Doctrine, which requires courts to defer to agency interpretations of ambiguous statutes, thereby...more
7/3/2024
/ Administrative Procedure Act ,
Chevron Deference ,
Chevron v NRDC ,
Government Agencies ,
Healthcare ,
Loper Bright Enterprises v Raimondo ,
Medicare ,
National Marine Fisheries Service ,
Regulatory Authority ,
Reimbursements ,
SCOTUS ,
Statutory Interpretation
CMS estimates that between 2017 and 2021, Medicare Part A improperly paid $23.9 billion for inpatient hospital stays, with $7.8 billion attributable to short stays that did not qualify for Medicare Part A. On June 13, 2024,...more
6/20/2024
/ Centers for Medicare & Medicaid Services (CMS) ,
Enforcement ,
Hospitals ,
Inpatient Billing ,
Medicare ,
Medicare Part A ,
Noncompliance ,
OIG ,
Outpatient Services ,
Overpayment ,
Payment Systems ,
Reimbursements ,
Two-Midnight Rule
On May 8, 2024, CMS issued a proposed rule for establishing the Increasing Organ Transplant Access Model (IOTA Model). As proposed, the IOTA Model would run for six years starting on January 1, 2025, in Donation Service Areas...more
Last week, the Biden-Harris administration (the Administration) announced a new rule simplifying the process for enrolling in Medicaid, the Children’s Health Insurance Program (CHIP), and the Basic Health Program (BHP)....more