Articles and Blogs

This time things are really going to change. On January 9, 2017, the Centers for Medicare & Medicaid Services (“CMS”) released a pre-publication copy of the Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing, with only a few changes, the significant changes they proposed to... READ MORE

Pursuant to its recently issued final rule (“Rule”), CMS is implementing two cardiac-related episode payment models (“EPMs”). One of the EPMs pertains to episodes of care surrounding an acute myocardial infarction (“AMI EPM”); the other EPM pertains to episodes of care surrounding a coronary artery bypass graft (“CABG EPM”). Generally, participation in the AMI... READ MORE

On December 23, 2016, the Department of Health and Human Services, Office of Inspector General (“OIG”) released a report (the “Report”) detailing a case review of inpatient rehabilitation (“rehab”) hospitals.1 The Report indicates that for 39 out of 426 rehab hospital stays reviewed, the patient was unable to participate in and benefit significantly from... READ MORE

As the health care industry and the related body of health law shift like tectonic plates, Hall Render attorneys are committed to providing practical counsel and insight to health care providers. Below is a compilation of key developments from 2016 that will continue to impact the health care industry in 2017. As the new... READ MORE

Senate Takes First Step Towards ACA Repeal On January 4, the U.S. Senate took the first step towards repeal of the Affordable Care Act (“ACA”). The Senate voted 51-48 to advance a fiscal 2017 budget resolution (S. Con Res 3) that allows Congress to use the parliamentary procedure known as budget reconciliation to repeal... READ MORE

Contract management plays an important role in the day-to-day operations of any hospital or health system. With increased governmental scrutiny on hospital and physician arrangements, the need to ensure and track compliance across a health system’s portfolio of contracts is vital. An effective contract management program helps a health system to implement appropriate controls... READ MORE

The role of pharmacists and pharmacies as integral cogs in the patient care continuum continues to grow, thanks in no small part to incentives encouraging integrated and coordinated care designed to enable improved outcomes at lower cost. From Medicare bundled payment initiatives that include drug costs to third party payor reimbursement reductions driven by... READ MORE

On December 7, 2016, the Senate passed the 21st Century Cures Act (“Cures Act”), which revised Section 603 of the Bipartisan Budget Act of 2015 (“Section 603”) to provide an exception for off-campus provider-based departments (“PBDs”) that were mid-build or under development prior to November 2, 2015. The Cures Act was signed into law by... READ MORE