Publications by Regan E. Tankersley

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Medicare 14-Day Rule Enforcement Action

[01/29/25]

Congress Passes Extension to Key Telehealth Payment Policies

[12/24/24]

Contributing author for "Representing Hospitals and Health Systems, Second Edition." AHLA (November, 2024),

[11/25/2024]

Key Highlights from the 2025 Medicare Physician Fee Schedule Proposed Rule

[09/10/24]

CMS Releases Final Rule: Transforming Episode Accountability Model

[09/05/24]

CMS Announces Proposed Rule: Transforming Episode Accountability Model “TEAM”

[05/10/24]

Quoted in "Your Medicare coverage is hugely influenced by something called ‘the two-midnight rule.’ Here’s what that is," Fortune (March, 2024).

Medicare Advantage Plans Must Follow the Two-Midnight Rule

[11/17/23]

Medicare Exact Match Update: Provider Compliance Required Effective 8/1/2023

[07/28/23]

Medicare Physician Fee Schedule for 2023: What Providers Need to Know

[12/30/22]

New CMS Payment Model Aims to Improve Cancer Care

[07/12/22]

CMS Finalizes Co-Location Guidance: Uncertainty Remains

[11/18/21]

Final Rule for 2022 OPPS/ASC Payment Addresses Price Transparency Penalties, Covered Procedures Criteria and Much More

[11/16/21]

Key Medicare Payment Policy Changes from the CMS CY 2022 MPFS Final Rule

[11/16/21]

Medicare Telehealth Update for CY 2022

[11/10/21]

Quoted in "CMS reevaluating hospital outpatient pay rate cut exemptions," Modern Healthcare (September 2021).

[09/26/2021]

The Future of Telehealth: Examining “What’s Next”

[03/16/21]

Quoted in "Hospitals Get 'Raw Deal' as CMS Rejects Siteneutral Pay Cut Exemptions," Modern Healthcare (January 2021.)

Medicare Payment for COVID-19 Vaccines and Antibody Therapy

[12/21/20]

CMS Finalizes 2021 MPFS Final Rule – 3 Key Policy Changes Impacting Flexibility for Non-Physician Practitioners

[12/16/20]

CMS Accepting Waiver Applications to Permit Hospital Care at Home

[11/30/20]

CMS Finalizes New Mandatory Payment Model for ESRD Treatments

[10/19/20]

Telehealth Boom Continues: CMS Adds New Covered Services

[10/16/20]

CMS Reducing Payment for COVID-19 Lab Testing

[10/16/20]

CMS Updates: COVID-19 Data Reporting and Enforcement Process for Hospitals that Fail to Report

[10/14/20]

CMS Finalizes New Mandatory Radiation Oncology Payment Model

[09/29/20]

CMS Interim Final Rule – Increased Requirements and Enforcement for Data Reporting and Lab Testing

[08/27/20]

CMS Releases CY 2021 OPPS and ASC Proposed Rule

[08/06/20]

Telehealth Expansion: Proposed 2021 Physician Fee Schedule Updates and Planning for the New Normal

[08/04/20]

Provision of Telehealth Equipment: Updated COVID-19 Guidance

[05/13/20]

CMS Flexibilities for Relocation of Provider-Based Hospital Departments During the COVID-19 Public Health Emergency

[05/07/20]

CMS Flexibilities for Billing Hospital Outpatient Therapeutic Services During the COVID-19 Public Health Emergency

[05/05/20]

CMS Expands Upon Prior Telehealth Waivers as Part of COVID-19 Response

[05/01/20]

CMS Provides New Avenues for Freestanding EDs to Participate in Medicare and Medicaid

[04/29/20]

CMS Telehealth Expansion for RHCs and FQHCs

[04/20/20]

Hospital Exact Match Claim Edits Further Delayed Amidst COVID-19 Pandemic

[03/25/20]

CMS Confirms Provider’s Home Acceptable for Distant Site Telehealth Services

[03/24/20]

COVID-19 Results in Removal of DEA Controlled Substance Prescribing Limitations for Telemedicine

[03/17/20]

Medicare Telehealth Waivers Now Implemented with Significant Expansion

[03/17/20]

Key Takeaways from 2020 Hospital Outpatient Prospective Payment System Final Rule

[11/08/19]

Proposed CMS Hospital Survey Could Support CMS’s Efforts to Reduce 340B Drug Reimbursement

[10/07/19]

Hospitals Win Battle Over Site-Neutral Pay Cuts

[09/18/19]

CMS’s Reach May Be Limited in Bankruptcy Proceedings

[09/17/19]

Can Individuals and Hospitals Sue Wrongdoers Under the Medicare Secondary Payer Act?

[09/17/19]

MIPS Targeted Review Request Deadline September 30

[09/05/19]

Appropriate Use Criteria for Advanced Diagnostic Imaging – Testing Period Begins Soon!

[08/26/19]

CMS Proposes Payment Policy Changes Impacting Hospital Outpatient Department Services – What You Need to Know

[08/02/19]

CMS Proposed Mandatory Payment Models for Radiation Oncology and ESRD

[07/22/19]

Location Matters Update: CMS Postpones Exact Match Billing Rule – AGAIN

[07/02/19]

Medicare Hospital Co-Location Fix? Not There Yet…

[05/07/19]

CMS Postpones Rules for Billing Off-Campus Provider-Based Departments Until July 2019

[03/29/19]

Location Matters: Get It Right or Don’t Get Paid

[03/06/19]

Clinical Diagnostic Labs Enter a New Collection and Reporting Period as Medicare Payment Updates Continue

[01/18/19]

CMS Finalizes Several Changes for Off-Campus Provider-Based Clinics

[11/12/18]

CMS Letter to Clinicians – E/M Documentation Update

[11/09/18]

Quoted in “Hospitals Hit By 340B and Site-Neutral Medicare Cuts in New Rule,” HFMA (November 2018).

OIG Audit Findings: Many Inpatient Rehabilitation Facility Stays Did Not Meet Medicare Requirements (October 10, 2018)

[10/17/18]

CMS Proposes to Simplify Coding and Documentation Requirements for E/M Services but with a Catch

[09/28/18]

CMS Proposes Several Changes for Off-Campus Provider-Based Clinics

[08/03/18]

CMS Proposes to Eliminate Written Physician Order Requirement as a Condition for Payment for Inpatient Admissions

[05/08/18]

Hyperbaric Oxygen Therapy Services: 2017 OIG Work Plan Initiative Finds 85 Percent of Claims Billed in Error

[04/26/18]

Finally, a Permanent Fix to the Therapy Caps

[03/27/18]

Overreaching Edits Deactivated for CAH Method II Claims

[03/07/18]

CMS Guidance May Prevent Inpatient Rehabilitation Claim Denials

[03/05/18]

CMS Adopts National Targeted Probe and Educate Program

[02/06/18]

D.C. Circuit: CMS Manuals Are Policy Statements, Not Binding Authority

[01/30/18]

Medicare Therapy Caps – Expiration of Exception Processes and Applicability to Hospital Outpatient Services

[01/30/18]

Provider-Based Mid-Build Exception Starts to Pay Off for Hospitals

[01/15/18]

CMS Guidance Impacts Micro Hospitals

[10/05/17]

CMS Clarifies Definition of Hospital: What It Means to Be “Primarily Engaged”

[09/07/17]

CMS’s Unfounded “Theory of Relativity” – Major Payment Decrease Proposed for Non-Grandfathered Provider-Based Clinics

[07/24/17]

MACs Issue Revised Credentialing Guidance for Hospital Sleep Centers

[05/12/17]

Sleep Centers Wake Up to Medicare Accreditation Changes

[05/05/17]

21st Century Cures Act Provides Legislative Remedy for Mid-Build Off-Campus Provider-Based Departments

[12/09/16]

CMS Final Rule Implements Section 603 Limitations on Payment for Off-Campus Provider-Based Departments

[11/03/16]

CMS Leaves Many Unanswered Questions in Proposed Rules for Off-Campus Provider-Based Exclusion

[07/08/16]

Provider-Based Takes Another Hit in a Recent OIG Report

[07/01/16]

CMS to Consider Provider-Based Concerns with Budget Act Implementation

[04/06/16]

CMS Proposes Enhanced Provider Enrollment Disclosure Obligations and Enforcement Authority

[03/07/16]

CMS Issues Final Overpayment Refund Rule

[02/12/16]

CMS Posts “PO Modifier” Frequently Asked Questions

[01/28/16]

Advanced Care Planning an Optional Element of an Annual Wellness Visit

[01/11/16]

Reminder: New Billing Requirements for Off-Campus Provider-Based Departments Effective January 1, 2016

[12/21/15]

Quoted in “Protect Your Practice, Don’t Overexplain When Voluntarily Repaying Overpayments,” Part B News (December 2015).

Provider-Based: The Visiting Specialist Solution to CMS’s Evolving Exclusive Use Standard

[11/24/15]

Budget Blast: Exclusion of Hospital Payment for “New” Off-Campus Hospital Departments

[11/03/15]

House Budget Bill Targets New Off-Campus Hospital Departments

[10/29/15]

What’s New with the 2-Midnight Rule?

[07/31/15]

U.S. Supreme Court Rejects Private Causes of Action Challenging Medicaid Reimbursement Levels

[03/31/15]

New CMS Regulation Targets Billing Privileges

[12/11/14]

Privileged Compliance Investigations: A Strategy for Avoiding Retained Overpayment FCA Actions

[07/02/14]

AHA Comments to Medicare 2015 Inpatient Rule

[06/27/14]

CMS Announces the Creation of a Medical Review Provider Relations Coordinator

[06/06/14]

CMS Extends 2-Midnight Rule Enforcement Delay

[05/13/14]

OIG Releases Report Recommending Reduction of OPPS Payment Rates to ASC Rates

[05/01/14]

MedPAC Recommends Decreasing Payments for Hospital Outpatient Services

[02/06/14]

CMS Publishes 2014 Outpatient Prospective Payment System and Ambulatory Surgical Center Final Rule

[12/09/13]

CMS Publishes 2014 Physician Fee Schedule Final Rule

[12/06/13]

CMS Delays Full Implementation of the 2-Midnight Rule Until January 1, 2014

[10/01/13]

CMS Final Rule Providing Additional Part B Payment to Hospitals Denied Part A Inpatient Payment

[09/25/13]

2014 IPPS Final Rule – CMS Clarifies Inpatient Admission Criteria to Reduce Payment Uncertainty

[08/14/13]

D.C. Circuit Upholds Medicare Overpayment Extrapolation Determination

[08/01/13]

Time Equals Money: Recent Change to Medicare Overpayment Recovery Period

[01/24/13]

CMS Issues Proposed Rule to Implement Statutory Obligation to Report and Return Overpayments

[02/17/12]

OIG Alert on Reassignment Raises Concern for Physicians

[02/09/12]

Medicare’s Supervision Policy for CY 2012

[12/30/11]

Medicare Changes to the 3-Day Payment Window Rule Impact Physician Billing in 2012

[11/08/11]

Medicare Changes to the 3-Day Window Rule

[08/10/11]

Medicare Changes to the 3-Day Window Rule

[08/08/11]

CMS Issues FFY 2012 IPPS Final Rule

[08/02/11]

Advanced Diagnostic Imaging Accreditation Deadline – January 1, 2012

[07/06/11]

CMS Proposes to Rescind Signature Requirement on Lab Requisitions

[07/01/11]

CMS Proposes Rule to Revise Certain DMEPOS Supplier Standards

[04/08/11]

CMS Proposes Rule to Implement Value-Based Purchasing Program for IPPS Hospitals

[01/21/11]