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CMS Proposes New Mandatory, Two-Sided Risk Model for Heart Failure and Low Back Pain

Key Takeaways - CMS has proposed a mandatory two-sided risk model for specialists treating heart failure and low back pain in outpatient settings....more

Top Questions Health Care Providers Should Consider in a Post-Chevron World – A Polsinelli Round Table Discussion

Health Care is one of the most regulated industries in the country, and for many years, one of the key administrative agencies overseeing health care in the United States, the Department of Health and Human Services’ (“HHS”)...more

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

HHS and CMS Finalize Historic Changes to Medicare Fraud and Abuse Laws

On November 20, 2020, the Department of Health and Human Services (HHS), Office of Inspector General (OIG), and the Centers for Medicare and Medicaid Services (CMS) finalized three rules making historic changes to three of...more

CMS “Hospitals Without Walls” Flexibilities – New Opportunities And Risks

One of the most frightening risks of the COVID-19 pandemic is the potential for health systems to become overwhelmed. Houston, like many other regions of the country has seen rapid, often unpredictable increases of cases...more

CMS Recommendations For Re-Opening Heath Care Facilities For Non-Emergent Medical Services

On April 19, 2020, the Centers for Medicare and Medicaid Services (CMS) issued new updated recommendations for providers to restart the provision care to patients without symptoms of COVID-19 entitled Re-opening Facilities to...more

Analyzing the Proposed 2019 Stark Reforms

The United Stated Department of Health and Human Services (“HHS”) published a notice of proposed rulemaking (NPRM) containing proposed changes to the Physician Self-Referral Law (“Stark Law,” or “Stark”) on October 17, 2019....more

CMS Launches New Primary Care Payment Models

On April 22, 2019, the Centers for Medicare and Medicaid Services (“CMS”) announced four new voluntary payment models that could allow primary care practitioners like physicians or advanced practice nurses, hospitals or other...more

The Path Forward - Big Decisions Ahead for ACOs under MSSP Final Rule

The December 21, 2018 “Pathways to Success” final rule governing Accountable Care Organizations participating in the Medicare Shared Savings Program (MSSP) will require expedited migration to financial risk arrangements. The...more

CMS “Goes Fishing” on Stark Law’s Impediments to Value-Based, Coordinated Care

On June 20, 2018, the Centers for Medicare & Medicaid Services and Department of Health and Human Services issued a “request for information” (RFI) seeking input on strategies to reduce the burden of the federal physician...more

Newly-Announced 340B Payment Rule Presents Financial & Operational Challenges to All Covered Entities

In its 2018 Outpatient Prospective Payment System final rule (Final Rule) issued Nov. 1, Centers for Medicare and Medicaid Services (CMS) implemented a significant Medicare Part B payment reduction for separately payable,...more

Dealing with Disasters – Quality Payment Program Exception Available for MIPS-Participating Clinicians and Groups

The Centers for Medicare & Medicaid Services (CMS) simplified the process for clinicians and other providers to seek the Quality Payment Program (QPP) Hardship exception by releasing an online application on Aug. 2....more

MACRA: Proposed Changes to the Merit-Based Incentive Payment System Track

The Centers for Medicare & Medicaid Services (CMS) published a proposed rule on the Medicare Quality Payment Program (QPP) in the Federal Register1 on June 30, 2017. This rule proposes the QPP program requirements for...more

340B Covered Entities Beware: CMS Proposes Drastic Drug Reimbursement Rate Cuts

In its Outpatient Prospective Payment System proposed rule ("Proposed Rule"), CMS outlined a significant Medicare Part B payment reduction for separately payable, nonpassthrough drugs provided in the hospital outpatient...more

Stark Law: What Providers Should Know About New CMS Form

The Centers for Medicare and Medicaid Services (CMS) has finalized Form CMS-10328 (the SRDP Form), a new OMB-approved information collection instrument that must be used by providers and suppliers utilizing the Stark Law...more

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